Weston County School District No. One

2025-003 U.S. Department of Education, Special Education Cluster (CFDA 84.027 and 84.173),U.S. Department of Education, Title 1 Grants to Local Education Agencies (CFDA 84.010) U.S. Department of Agriculture, Child Nutrition Cluster (CFDA 10.553 and 10.555)2025-001 Separation of Duties Criteria: An effective internal control structure of an organization will include procedures and actions to: 1. Protect its assets against theft and waste. 2. Ensure compliance with the organization's policies, procedures and statutory requirements. 3. Evaluate the performance of personnel to promote efficient operations. 4. Ensure accurate and reliable operating and accounting dataSeparation of duties requires that someone other than the employee responsible for safeguarding the asset must maintain the accounting records for that asset. When an organization separates duties of the employees, it minimizes the probability of an error or irregularity occurring and not being timely detected Condition: Due to the small size of the accounting department of the District, the possibility of adequate separation of duties over certain transaction cycles is limited. Potential Effect of Condition: There is an increased risk that errors or irregularities might not be detected in a timely manner in the course of employees performing their assigned duties. Recommendation: While we recognize that it is impractical for the District to achieve complete separation of duties over all transaction cycles within the District, it is important that the Board be aware of the chance of errors and irregularities not being timely detected is elevated. Auditee Response: The District has separated duties to the extent possible and has implemented compensating controls to monitor the accounting activities.

The District has separated duties to the extent possible and has implemented compensating controls to monitor the accounting activities

2024-002

2024-001 Separation of Duties Criteria: An effective internal control structure of an organization will include procedures and actions to: 1. Protect its assets against theft and waste. 2. Ensure compliance with the organization's policies, procedures and statutory requirements. 3. Evaluate the performance of personnel to promote efficient operations. 4. Ensure accurateSeparation of duties requires that someone other than the employee responsible for safeguarding the asset must maintain the accounting records for that asset. When an organization separates duties of the employees, it minimizes the probability of an error or irregularity occurring and not being timely detected Condition: Due to the small size of the accounting department of the District, the possibility of adequate separation of duties over certain transaction cycles is limited. Recommendation: While we recognize that it is impractical for the District to achieve complete separation of duties over all transaction cycles within the District, it is important that the Board be aware of the chance of errors and irregularities not being timely detected is elevated. Auditee Response: The District has separated duties to the extent possible and has implemented compensating controls to monitor the accounting activities. and reliable operating and accounting data.

The District has separated duties to the extent possible and has implemented compensating controls to monitor the accounting activities.

2023-002

Criteria: An effective internal control structure of an organization will include procedures and actions to:1. Protect its assets against theft and waste2. Ensure compliance with the organization's policies, procedures and statutory requirements3. Evaluate the performance of personnel to promote efficient operations4. Ensure accurate and reliable operating and accounting data. Separation of duties requires that someone other than the employee responsible for safeguarding the asset must maintain the accounting records for that asset. When an organization separates duties of the employees, it minimizes the probability of an error or irregularity occurring and not being timely detectedCondition: Due to the small size of the accounting department of the District, the possibility of adequate separation of duties over certain transaction cycles is limited. Recommendation: While we recognize that it is impractical for the District to achieve complete separation of duties over all transaction cycles within the District, it is important that the Board be aware of the chance of errors and irregularities not being timely detected is elevated. Auditee Response: The District has separated duties to the extent possible and has implemented compensating controls to monitor the accounting activities.

The District has separated duties to the extent possible and has implemented compensating controls to monitor the accounting activities

Davis Bacon Compliance Criteria: The compliance requirements for the Educational Stabilization Fund requires the District comply with the provisions of the Davis Bacon Act for construction contracts thee District has entered into. The Davis-Bacon Act requires contractors and subcontractors performing on contracts pay local prevailing wages on public works projects for laborers and mechanics. The Davis-Bacon Act applies to federally-funded or assisted contracts in excess of $2,000 for construction, alteration, or repair of public buildings or public works. The governmental entity is required to monitor the contractor compliance with the paying the prevailing wage rate. To accomplish this compliance the contractor is required to submit certified payroll reports to the governmental entity or an agent of the entity. Certified payroll reports are comprehensive federal reports (WH-347) that are submitted to the agency in charge of the government contract. It lists all employees, their wage, benefits, type of work they did, and hours worked each week. Condition: The contractors in question did not provide the necessary certified payroll reports to the District. Recommendation: In the future the District should follow the provisions for the Davis Bacon Act which includes obtaining weekly certified payrolls from contractors to which the provision apply. Auditee Response: The United States Department of Education (USED) updated their requirements for the Davis-Bacon Act (DBA) provisions. With the updated requirements, Weston County School District #1 was notified that all contracted building, installation, surveying, demolition/removal work, or other construction projects supported by ESSER funding must submit weekly certified payroll documentation for every contract more than $2, 000. Weston County School District #1 is diligently working to gather payroll documentation from vendors for all projects that are ongoing/completed, paid for with ESSER monies, and are more than $2,000. As the requirement is retroactive, this process can be timely. The documentation will be submitted to the state as the district receives the payroll documentation from vendors.

The United States Department of Education (USED) updated their requirements for the Davis-Bacon Act (DBA) provisions. With the updated requirements, Weston County School District #1 was notified that all contracted building, installation, surveying, demolition/removal work, or other construction projects supported by ESSER funding must submit weekly certified payroll documentation for every contract more than $2, 000. Weston County School District #1 is diligently working to gather payroll documentation from vendors for all projects that are ongoing/completed, paid for with ESSER monies, and are more than $2,000. As the requirement is retroactive, this process can be timely. The documentation will be submitted to the state as the district receives the payroll documentation from vendors.

FINDINGS - FINANCIAL STATEMENTS AUDIT SIGNIFICANT DEFICIENCIES 2022-001 Separation of Duties Criteria: An effective internal control structure of an organization will include procedures and actions to: 1. Protect its assets against theft and waste. 2. Ensure compliance with the organization's policies, procedures and statutory requirements. 3. Evaluate the performance of personnel to promote efficient operations. 4. Ensure accurate and reliable operating and accounting data. Separation of duties requires that someone other than the employee responsible for safeguarding the asset must maintain the accounting records for that asset. When an organization separates duties of the employees, it minimizes the probability of an error or irregularity occurring and not being timely detected Condition: Due to the small size of the accounting department of the District, the possibility of adequate separation of duties over certain transaction cycles is limited. Recommendation: While we recognize that it is impractical for the District to achieve complete separation of duties over all transaction cycles within the District, it is important that the Board be aware of the chance of errors and irregularities not being timely detected is elevated. Auditee Response: The District has separated duties to the extent possible and has implemented compensating controls to monitor the accounting activities. FINDINGS - MAJOR FEDERAL AWARDS PROGRAMS AUDIT U.S. Department of Education, Educational Stabilization Fund (CFDA 84.425) and U.S. Department of Treasury, CARES (CFDA 21.019) 2022-002 Separation of Duties Reportable Condition: Refer to Item 2021-001 in the Findings - Financial Statements Audit for discussion regarding this item.

To Whom it May Concern: Due to the District?s small office staff, it makes it impractical for the District to achieve full separation of the accounting functions with the business office. We are unable to fully segregate the accounting functions of approval, accounting\reconciling, and asset custody. The District has mitigated the risks associated with this limitation through use of various compensating controls and segregating the functions to the extent reasonably possible. This has been accomplished by placing various levels into the approval process for payroll and cash disbursements, and this is evidenced through an audit trail for approval at each level of approval. Accounting reports are reviewed monthly for discrepancies and errors. The governing board is also involved in the approval process as the final authority over payment approval. The District also has formal policy procedure manuals for accounting controls procedures and follows Wyoming State Statutes to mitigate to as low as level as possible any risk of errors or irregularities and to timely detect any such errors or irregularities. The accounting staff, management and the School Board are fully aware of the situation and therefore on heightened awareness in performing their duties to further mitigate any risks that have not been mitigated. Sincerely, Angela Holliday Business Manager

2021-002

2021-002 Separation of DutiesCriteria: An effective internal control structure of an organization will include procedures and actions to:1. Protect its assets against theft and waste.2. Ensure compliance with the organization's policies, procedures and statutory requirements.3. Evaluate the performance of personnel to promote efficient operations.4. Ensure accurate and reliable operating and accounting data.Separation of duties requires that someone other than the employee responsible for safeguarding the asset must maintain the accounting records for that asset. When an organization separates duties of the employees, it minimizes the probability of an error or irregularity occurring and not being timely detectedCondition: Due to the small size of the accounting department of the District, the possibility of adequate separation of duties over certain transaction cycles is limited.Recommendation: While we recognize that it is impractical for the District to achieve complete separation of duties over all transaction cycles within the District, it is important that the Board be aware of the chance of errors and irregularities not being timely detected is elevated.Auditee Response: The District has separated duties to the extent possible and has implemented compensating controls to monitor the accounting activities.

Due to the District?s small office staff, it makes it impractical for the District to achieve full separation of the accounting functions with the business office. We are unable to fully segregate the accounting functions of approval, accounting\reconciling, and asset custody. The District has mitigated the risks associated with this limitation through use of various compensating controls and segregating the functions to the extent reasonably possible. This has been accomplished by placing various levels into the approval process for payroll and cash disbursements, and this is evidenced through an audit trail for approval at each level of approval. Accounting reports are reviewed monthly for discrepancies and errors. The governing board is also involved in the approval process as the final authority over payment approval.The District also has formal policy procedure manuals for accounting controls procedures and follows Wyoming State Statutes to mitigate to as low as level as possible any risk of errors or irregularities and to timely detect any such errors or irregularities. The accounting staff, management and the School Board are fully aware of the situation and therefore on heightened awareness in performing their duties to further mitigate any risks that have not been mitigated.

FINDINGS - FINANCIAL STATEMENTS AUDIT SIGNIFICANT DEFICIENCIES 2020-001 Separation of Duties Criteria: An effective internal control structure of an organization will include procedures and actions to: 1. Protect its assets against theft and waste. 2. Ensure compliance with the organization's policies, procedures and statutory requirements. 3. Evaluate the performance of personnel to promote efficient operations. 4. Ensure accurate and reliable operating and accounting data. FINDINGS - FINANCIAL STATEMENTS AUDIT SIGNIFICANT DEFICIENCIES 2020-001 Separation of Duties Criteria: An effective internal control structure of an organization will include procedures and actions to: 1. Protect its assets against theft and waste. 2. Ensure compliance with the organization's policies, procedures and statutory requirements. 3. Evaluate the performance of personnel to promote efficient operations. 4. Ensure accurate and reliable operating and accounting data. Separation of duties requires that someone other than the employee responsible for safeguarding the asset must maintain the accounting records for that asset. When an organization separates duties of the employees, it minimizes the probability of an error or irregularity occurring and not being timely detected Condition: Due to the small size of the accounting department of the School District, the possibility of adequate separation of duties over certain transaction cycles is limited. Recommendation: While we recognize that it is impractical for the School District to achieve complete separation of duties over all transaction cycles within the School District, it is important that the Board be aware of the chance of errors and irregularities not being timely detected is elevated. Auditee Response: The District has separated duties to the extent possible and has implemented compensating controls to monitor the accounting activities. FINDINGS - MAJOR FEDERAL AWARDS PROGRAMS AUDIT DEPARTMENT OF EDUCATION Title 1 (CFDA 84.010) Passed through Wyoming Department of Education 2020-002 Separation of Duties Reportable Condition: Refer to Item 2020-001 in the Findings - Financial Statements Audit for discussion regarding this item.

Due to the District's small office staff, it makes it impractical for the District to achieve full separation of the accounting functions with the business office. We are unable to fully segregate the accounting functions of approval, accounting\reconciling, and asset custody. The District has mitigated the risks associated with this limitation through use of various compensating controls and segregating the functions to the extent reasonably possible. This has been accomplished by placing various levels into the approval process for payroll and cash disbursements, and this is evidenced through an audit trail for approval at each level of approval. Accounting reports are reviewed monthly for discrepancies and errors. The governing board is also involved in the approval process as the final authority over payment approval. The District also has formal policy procedure manuals for accounting controls procedures and follows Wyoming State Statutes to mitigate to as low a level as possible any risk or errors or irregularities and to timely detect any such errors or irregularities. The accounting staff, management and the School Board are fully aware of the situation and therefore on heightened awareness in performing their duties to further mitigate any risks that have not been mitigated.

FINDINGS - MAJOR FEDERAL AWARDS PROGRAMS AUDIT DEPARTMENT OF EDUCATION AFTER SCHOOL LEARNING CENTERS (CFDA 84.287) Passed through Wyoming Department of Education 2019-002 Separation of Duties Reportable Condition: Refer to Item 2019-001 in the Findings - Financial Statements Audit for discussion regarding this item. 2019-001 Separation of Duties Criteria: An effective internal control structure of an organization will include procedures and actions to: 1. Protect its assets against theft and waste. 2. Ensure compliance with the organization's policies, procedures and statutory requirements. 3. Evaluate the performance of personnel to promote efficient operations. 4. Ensure accurate and reliable operating and accounting data. Separation of duties requires that someone other than the employee responsible for safeguarding the asset must maintain the accounting records for that asset. When an organization separates duties of the employees, it minimizes the probability of an error or irregularity occurring and not being timely detected Condition: Due to the small size of the accounting department of the School District, the possibility of adequate separation of duties over certain transaction cycles is limited. Recommendation: While we recognize that it is impractical for the School District to achieve complete separation of duties over all transaction cycles within the School District, it is important that the Board be aware of the chance of errors and irregularities not being timely detected is elevated. Auditee Response: The District has separated duties to the extent possible and has implemented compensating controls to monitor the accounting activities.

Due to the District?s small office staff, it makes it impractical for the District to achieve full separation of the accounting functions with the business office. We are unable to fully segregate the accounting functions of approval, accounting\reconciling, and asset custody. The District has mitigated the risks associated with this limitation through use of various compensating controls and segregating the functions to the extent reasonably possible. This has been accomplished by placing various levels into the approval process for payroll and cash disbursements, and this is evidenced through an audit trail for approval at each level of approval. Accounting reports are reviewed monthly for discrepancies and errors. The governing board is also involved in the approval process as the final authority over payment approval. The District also has formal policy procedure manuals for accounting controls procedures and follows Wyoming State Statutes to mitigate to as low as level as possible any risk of errors or irregularities and to timely detect any such errors or irregularities. The accounting staff, management and the School Board are fully aware of the situation and therefore on heightened awareness in performing their duties to further mitigate any risks that have not been mitigated.

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