Fremont County School District #1Local Government

Criteria or Specific Requirement Education Stabilization Fund requires that grantees must submit an annual performance report (OMB No. 1810-0749 for Elementary and Secondary School Emergency Relief; and 1810-0765 for Emergency Assistance to Nonpublic Schools) with data on expenditures, planned expenditures, sub recipients, and uses of funds, including mandatory reservations. Local Education Agencies submit data to the State Education Agency/Governor for the State Education Agency’s/Governor report. Reporting compliance requirements state that required reports for federal awards should be supported by applicable accounting or performance records. Condition Policies and procedures for the retention of documentation supporting data on ESSER reports submitted to the Wyoming Department of Education were not followed. Cause The District’s management and grant personnel prepared the report in collaboration with several individuals to assure understanding of the information required and accuracy of the information. After preparation and submission of the reports, supporting documentation was not retained. Effect or Potential Effect The documentation supporting the data and other information submitted in the ESSER reports to Wyoming Department of Education had to be recreated. Questioned Costs None Context The District did not retain supporting documentation for the data included in the annual ESSER reports submitted to the Wyoming Department of Education. Identification of a Repeat Finding This is a repeat finding. Recommendation We recommend the District review its policies and procedures regarding submission of reports to granting agencies to assure the documentation supporting the reported data reported is retained. Views of Responsible Officials In the future all supporting documentation will be retained by Business Office personnel and kept in the audit file. See Corrective Action Plan

Criteria or Specific Requirement Per 2 CFR Part 200 and the ESSER Grant Award Terms & Conditions, the District must comply with the Davis-Bacon Act for construction-related activity. Contractors must submit weekly certified payrolls (29 CFR 5.5(a)(3)(ii)) to demonstrate payment of prevailing wages, and the District must review these payrolls timely prior to approving invoices. Condition During testing the Special Tests and Provisions requirement for the ESSER program, we noted that certified payroll reports were not completed and/or submitted on a timely basis for contractors paid with ESSER funds. The District is required to obtain weekly certified payrolls from contractors and subcontractors performing construction activities to ensure prevailing wage compliance. For the items tested, 11 out of 13 certified payrolls were received between 2–32 weeks late, and in some instances were missing required certifications at the time of payment. Cause The District did not have a formalized process to collect, track, and review certified payrolls weekly. Communication between the contractor and District staff regarding required documentation was inconsistent, and no monitoring log was maintained. Effect or Potential Effect Without timely submission and review of certified payrolls, the District cannot ensure contractors were paid the required prevailing wage rates, increasing the risk of noncompliance with federal requirements. This could result in questioned costs or corrective action required by the State or federal agency. Questioned Costs None Context The District did not obtain timely weekly certified payrolls from contractor. Identification of a Repeat Finding This is a new finding for the fiscal year ended June 30, 2025. Recommendation We recommend the District establish a formal monitoring process for certified payrolls. Views of Responsible Officials For future projects of this nature that are funded with federal dollars the District will implement a written procedure to ensure weekly certified payrolls are obtained, reviewed, and documented prior to payment approval. The District will communicate these requirements to contractors and maintain a monitoring log going forward. See Corrective Action Plan

Criteria or Specific Requirement Eligibility - When determining eligibility, a LEA must select a poverty measure from among the following data sources: (1) the number of children ages 5–17 in poverty counted in the most recent census; (2) the number of children eligible for free and reduced price lunches; (3) the number of children in families receiving TANF; (4) the number of children eligible to receive Medicaid assistance; or (5) a composite of these data sources. The District selected the number of children eligible for free and reduced price lunches as the poverty measure. The District’s system of internal control must include review and retention of the documentation supporting the counts of children eligible for free and reduced lunches for all attendance areas reported in the grant application. The District may use the district-wide poverty average or the poverty average for the respective grade-span grouping. A LEA may serve, for one additional year, an attendance area that is not currently eligible but was eligible and served in the preceding year. The District’s system of internal control should include the review of the information reported to assure the accuracy and compliance with the program requirements Additionally, a school at or above 40 percent poverty or a school that receives a waiver from the SEA may use its Part A funds, along with other federal, state, and local funds, to operate a schoolwide program to upgrade the instructional program in the whole school. Condition The number of children eligible for free and reduced priced meals reported for four attendance areas in the grant application did not match to the counts recorded in the District’s student information management system, which maintains the data for children eligible for free and reduced priced meals. Reliable data from the information management system was either not used or was used but the record of the data was not maintained as support for the numbers included on the grant application. The information included on the grant application was not reviewed by another knowledgeable individual prior to submission. The District’s internal control system is lacking a review process of the grant application information resulting in an incorrect determination of poverty rate of the attendance areas. Cause The District does not have an established review process for verifying the accuracy of information reported in the grant application and has not retained the supporting documentation to substantiate the reported data. Effect or Potential Effect The District’s eligibility calculation was inconsistent with the supporting documentation from free and reduced lunch applications resulting in an incorrect determination of poverty rate in an attendance area. Questioned Costs None. Context The District’s low income student counts reported for five of its six attendance areas and one of its six attendance areas did not agree to the supporting information contained in the District’s student management system for the dates reported on the 2023 – 2024 and 2022 – 2023 grant applications, respectively. The counts reported for two of the attendance areas incorrectly resulted in poverty rate greater than 40% in the 2023 – 2024 grant application and one of the attendance areas incorrectly resulted in poverty rate greater than 40% in the 2022 – 2023 grant application. Identification of Repeat Finding This is not a repeat finding. Recommendation The District should obtain and retain student count information from the District’s student management system for the Title I grant application. Furthermore, once the grant application is completed, it should be reviewed by another knowledgeable individual. Views of Responsible Officials Fremont Count School District #1 will review and retain supporting documentation for the numbers of free and reduced lunch applicants in determining eligibility for the Title I grant. See Corrective Action Plan

Criteria or Specific Requirement Education Stabilization Fund requires that grantees must submit an annual performance report (OMB No. 1810-0749 for ESSER; and 1810-0765 for EANS) with data on expenditures, planned expenditures, sub recipients, and uses of funds, including mandatory reservations. LEAs submit data to the SEA/Governor for the SEA’s/Governor report. Reporting compliance requirements state that required reports for federal awards should be supported by applicable accounting or performance records. Condition Internal controls to the retention of documentation supporting data on ESSER reports submitted to the Wyoming Department of Education were not followed. Cause The District’s management and grant personnel prepared the report in collaboration with several individuals to assure understanding of the information required and accuracy of the information. After preparation and submission of the reports, supporting documentation was inadvertently not retained. Effect or Potential Effect The documentation supporting the data and other information submitted in the ESSER reports to Wyoming Department of Education had to be recreated. Questioned Costs None Context The District did not retain supporting documentation for the data included in the annual ESSER reports submitted to the Wyoming Department of Education. Identification of a Repeat Finding This is a repeat finding. Recommendation We recommend the District review its policies and procedures regarding submission of reports to granting agencies to assure the documentation supporting the reported data reported is retained. Views of Responsible Officials In the future, no matter how many different individuals are collecting data for reporting, all supporting documentation will be retained by Business Office personnel and kept in the audit file. See Corrective Action Plan

Criteria or Specific Requirement Suspension and Debarment – 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 that are expected to equal or exceed $25,000. When a non-federal entity enters into a covered transaction, the non-federal entity must verify that the entity or person is not suspended or debarred. 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 SAM.gov, (2) collecting a certification from the entity or person, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The non-federal entity must have internal controls designed and operating the ensure compliance with the suspension and debarment requirements. Condition Internal controls over entering into a transaction with a suspended or debarred party were not followed on an applicable purchase. Fremont County School District #1’s (“District”) management indicated that a search on SAM was performed; however, the SAM search results were not retained to document the compliance with the requirement. Cause The District’s grant personnel advised that the absence of SAM search documentation was missed during their review of the grant documentation. Effect or Potential Effect Without full compliance with the requirements for procurement, suspension and debarment, the District could be required to repay all amounts expended for these purchases. Questioned Costs None. Context The District had one transaction subject to the suspension and debarment compliance requirement. The District did not retain SAM search results to document compliance with verification that the contractor was not suspended or debarred prior to entering into the contract. Identification of a Repeat Finding No Recommendation We recommend the District review its policies and procedures to ensure compliance with suspension and debarment compliance requirement is documented. The District may consider collecting a certification from the entity or adding a clause or condition to the covered transaction with that entity. Additionally, the District may consider developing a checklist to make sure all required documentation is maintained in the grant file. Views of Responsible Officials Fremont Count School District #1 will modify its template contract used for these types of transactions to include a certification of compliance related to suspension and debarment from the person or entity, so that each contract entered into in the future will be compliant. See Corrective Action Plan.

Criteria or Specific Requirement Education Stabilization Fund requires that grantees must submit an annual performance report (OMB No. 1810-0749 for ESSER; 1810-0748 for GEER; and 1810-0765 for EANS) with data on expenditures, planned expenditures, sub recipients, and uses of funds, including mandatory reservations. LEAs submit data to the SEA/Governor for the SEA’s/Governor report. Reporting compliance requirements state that required reports for federal awards should be supported by applicable accounting or performance records. Condition Internal controls over retention of documentation supporting data on ESSER and GEER reports submitted to Wyoming Department of Education were not followed. Cause Education Stabilization Fund is a new grant. The District’s management and grant personnel prepared the report in collaboration with several individuals to assure understanding of the information required and accuracy of the information. After preparation and submission of the reports, supporting documentation was inadvertently not retained. Effect or Potential Effect Documentation to support data and other information submitted in ESSER and GEER reports to Wyoming Department of Education had to be recreated. Questioned Costs None Context The District did not retain supporting documentation included in the annual ESSER and GEER reports submitted to Wyoming Department of Education. Identification of a Repeat Finding No Recommendation We recommend the District review its policies and procedures regarding submission of reports to granting agencies to assure the documentation supporting the data reported is retained. Views of Responsible Officials In the future, no matter how many different individuals are collecting data for reporting, all supporting documentation will be retained by Business Office personnel and kept in the audit file. See Corrective Action Plan

2020-001 Material Weakness in Internal Control Material Noncompliance Identification of the federal program: U.S. Department of Education Passed through the Wyoming Department of Education 84.010 ? Title I Grants to Local Educational Agencies Federal award identification number: 200701T1SUBR1900 Grant year: 2019-2020 Criteria or Specific Requirement: Eligibility -When determining eligibility, a LEA must select a poverty measure from among the following data sources: (1) the number of children ages 5?17 in poverty counted in the most recent census; (2) the number of children eligible for free and reduced price lunches; (3) the number of children in families receiving TANF; (4) the number of children eligible to receive Medicaid assistance; or (5) a composite of these data sources. The District selected the number of children eligible for free and reduced price lunches as the poverty measure. The District?s system of internal control must include review and retention of the documentation supporting the counts of children eligible for free and reduced lunches for all attendance areas reported in the grant application. The District may use the district-wide poverty average or the poverty average for the respective grade-span grouping. A LEA may serve, for one additional year, an attendance area that is not currently eligible but was eligible and served in the preceding year. The District?s system of internal control should include the review of the information reported to assure the accuracy and compliance with the program requirements. Additionally, a school at or above 40 percent poverty or a school that receives a waiver from the SEA may use its Part A funds, along with other federal, state, and local funds, to operate a schoolwide program to upgrade the instructional program in the whole school. Condition: The number of children eligible for free and reduced priced meals reported for four attendance areas in the grant application did not agree to the counts reported in the District?s student information management system, which maintains the data for children eligible for free and reduced priced meals. Reliable data from the information management system was either not used or was used but the record of the data was not maintained as support for the numbers included on the grant application. The information included on the grant application was not reviewed by another knowledgeable individual. The District uses the district-wide poverty average to serve lower-poverty areas and schools. The District designated an attendance area below the district-wide poverty average for two years in a row. The District?s internal control system is lacking a review of the grant application information resulting in the District wrongfully selecting an attendance area below the district-wide poverty average for two years in a row. Cause: The District is lacking a review process and has not retained the supporting documentation of information reported in the grant. Effect or Potential Effect: The District?s attendance areas were incorrectly qualified as Title I and schoolwide eligible. Questioned Costs: Unknown. Context: The District?s low income student counts reported for four of its six attendance areas did not agree to the supporting information contained in the District?s student management system for the date reported on the 2019-2020 grant application. The counts reported for three of the attendance areas resulted in poverty rate greater than 40% when the actual percentages were between 24.22% to 38.96%. Additionally, the fourth attendance area was reported with a 34.48% poverty rate when the percentage based on the counts in the student management system was 32.18%. A LEA may serve, for one additional year, an attendance area that is not currently eligible but was eligible and served in the preceding year. This attendance area was eligible on this condition for the grant year 2018-2019; thus, it was not eligible in the grant year 2019-2020. Also, four of the District?s attendance areas qualified for a schoolwide program because the poverty rate in the 2019-2020 application was reported as greater than 40% when the actual percentages were less than 40%. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: The District should obtain and retain student count information from the District?s student management system for the Title I grant application. Furthermore, once the grant application is completed, it should be reviewed by another knowledgeable individual. Views of Responsible Officials: Please refer to the District?s corrective action plan.