EIN: 846001179
UEI: P4CNSL6HB853
Audited by: Forvis Mazars, LLP
Oversight agency: 84 [Department of Education]
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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 March 24, 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 24, 2026 (26 days from today).
What is a management decision? →FAC accepted this audit on November 13, 2024 — management decision was due May 13, 2025.
During our testing we noted the following: a. 3 out of the 25 payroll selections applied to the grant did not agree back to supporting payroll information. b. The indirect costs applied to the grant were not consistently applied between the quarters of the fiscal year due to variations in the indirect cost base used. Questioned Costs: a. $2,089. Questioned costs were determined by reviewing the payroll registers for the three impacted selections. b. None. The District under applied the amount of indirect costs allowable to the grant. Context: a. We tested 25 payroll, 25 nonpayroll and 25 fringe benefit transactions applied to the grant for the year ended June 30, 2024. The tested population covered expenditures of $7.1 million and the total population of expenditures were approximately $24.4 million. A non-statistical sampling methodology was used to select the sample. b. We tested the four quarters indirect costs calculations which were applied to the above grant award numbers for the year ended June 30, 2024. The tested population covered expenditures of $3.0 million and the total population of expenditures were approximately $3.1 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over the ESSER grant which resulted in unallowable costs being applied to the grant and inconsistently applying indirect costs to the grant. Cause: The District continued to experience turnover within the positions overseeing grants during fiscal year 2024. There were not detailed reviews over the calculations and supporting documentation used to determine the expenditure amount to be applied to the grant. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that the District strengthen the internal controls surrounding review of all expenditures applied against federal grants including the supporting detail or calculations used to determine the expenditure amount to help ensure it recalculates and is consistent with District polices and procedures. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.
Show full finding ▾Hide full finding ▴Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425U – COVID-19 – Elementary and Secondary School Emergency Relief Fund (ESSER III) Department of Education, Passed-Through Colorado Department of Education Award Number – 4414/4431/9414; Award Year 2021 Criteria: According to 2 CFR Part 200.403 factors affecting allowability of costs – costs must meet the following general criteria in order to be allowable under Federal awards: (a) be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity, (d) be accorded consistent treatment, (e) be determined in accordance with generally accepted accounting principles, (f) to be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period and (g) be adequately documented. In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing we noted the following: a. 3 out of the 25 payroll selections applied to the grant did not agree back to supporting payroll information. b. The indirect costs applied to the grant were not consistently applied between the quarters of the fiscal year due to variations in the indirect cost base used. Questioned Costs: a. $2,089. Questioned costs were determined by reviewing the payroll registers for the three impacted selections. b. None. The District under applied the amount of indirect costs allowable to the grant. Context: a. We tested 25 payroll, 25 nonpayroll and 25 fringe benefit transactions applied to the grant for the year ended June 30, 2024. The tested population covered expenditures of $7.1 million and the total population of expenditures were approximately $24.4 million. A non-statistical sampling methodology was used to select the sample. b. We tested the four quarters indirect costs calculations which were applied to the above grant award numbers for the year ended June 30, 2024. The tested population covered expenditures of $3.0 million and the total population of expenditures were approximately $3.1 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over the ESSER grant which resulted in unallowable costs being applied to the grant and inconsistently applying indirect costs to the grant. Cause: The District continued to experience turnover within the positions overseeing grants during fiscal year 2024. There were not detailed reviews over the calculations and supporting documentation used to determine the expenditure amount to be applied to the grant. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that the District strengthen the internal controls surrounding review of all expenditures applied against federal grants including the supporting detail or calculations used to determine the expenditure amount to help ensure it recalculates and is consistent with District polices and procedures. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.
2024-002 Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425U - COVID-19 - Elementary and Secondary School Emergency Relief Fund (ESSER III) Passed-through Colorado Department of Education Award Number - 4414/4431/9414; Award Year 2021 Summary of Finding: The District did not have adequate internal controls in place over the ESSER grant which resulted in unallowable costs being applied to the grant and inconsistently applying indirect costs to the grant. Status: Corrective action in progress Client Planned Action: The District concurs with the recommendations and is currently developing and implementing internal controls to ensure compliance. The inadequate internal controls that caused the inconsistency in supporting payroll information involved the End-of-Year Closeout process. The District will ensure End-of-Year Closeout procedures are up to date and adhered to. These procedures will include a second review of calculations used to determine the expenditure amount in accruals, to ensure it recalculates. The District will also conduct a second review of the supporting detail used to determine Indirect Costs to ensure they are consistent with CDE recommendations and District policies and procedures. Client Responsible Party: Annette Bass, Director of Grants Completion Date: Review of department End-of Year Closeout process began in September 2024. Adjustments and revisions will be made to these processes as needed, prior to End-of-Year Closeout, June 30, 2025.
The District did not have controls in place to identify that certified payrolls were not obtained for all subcontractors for construction projects which occurred during fiscal year 2024. Questioned Costs: None. Upon additional audit follow up requests, the contractor confirmed no work was performed during these weeks by the subcontractor. Context: We tested two construction projects out of the four construction projects which occurred during the year ended June 30, 2024. The tested population covered expenditures of $3.6 million and the total population of expenditures were approximately $6.5 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over to ensure that all certified payrolls were not obtained or reviewed for both the contractor and subcontractor so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Cause: The assigned employee to monitor, review and obtain certified payrolls during the year from contractors and subcontractors was out of the office for a portion of the year and the District did not have any employees trained as a backup. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the District implement additional internal controls over wage rate requirements, including cross-training employees to help ensure all certified payrolls or confirmation of no work performed are obtained timely. Views of Responsible Officials: Agree. See separate report for planned corrective actions.
Show full finding ▾Hide full finding ▴Finding: Special Tests – Wage Rate Requirements Federal Assistance Listing Number 84.425U – COVID-19 – Elementary and Secondary School Emergency Relief Fund (ESSER III) Department of Education, Passed-Through Colorado Department of Education Award Number – 4414/4431/9414; Award Year 2021 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have controls in place to identify that certified payrolls were not obtained for all subcontractors for construction projects which occurred during fiscal year 2024. Questioned Costs: None. Upon additional audit follow up requests, the contractor confirmed no work was performed during these weeks by the subcontractor. Context: We tested two construction projects out of the four construction projects which occurred during the year ended June 30, 2024. The tested population covered expenditures of $3.6 million and the total population of expenditures were approximately $6.5 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over to ensure that all certified payrolls were not obtained or reviewed for both the contractor and subcontractor so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Cause: The assigned employee to monitor, review and obtain certified payrolls during the year from contractors and subcontractors was out of the office for a portion of the year and the District did not have any employees trained as a backup. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the District implement additional internal controls over wage rate requirements, including cross-training employees to help ensure all certified payrolls or confirmation of no work performed are obtained timely. Views of Responsible Officials: Agree. See separate report for planned corrective actions.
2024-003 Finding: Special Tests - Wage Rate Requirements Federal Assistance Listing Number 84.425U - COVID-19 - Elementary and Secondary School Emergency Relief Fund (ESSER III) Passed-through Colorado Department of Education Award Number - 4414/4431/9414; Award Year 2021 Summary of Finding: The District did not have adequate internal controls in place to ensure that all certified Payrolls were obtained or reviewed for both the contractor and subcontractor, so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Status: Corrective action in progress Client Planned Action: The District concurs with the recommendations and is currently developing and implementing internal controls to ensure Compliance. Grants Dept. personnel met with Capital Construction and Procurement Personnel to discuss the processes and procedures to implement, and internal controls that would ensure this. The District’s Grants Department will: 1. Require departments/teams utilizing federally funded grants which involve construction/labor, to designate two staff members responsible for collection of wage-rate payroll certifications. 2. Conduct a meeting/training that involves all responsible parties, prior to any work being done, to establish processes/procedures to obtain, track, monitor, and review certified payrolls and compare them to prevailing wage rates. Client Responsible Party: Annette Bass, Director of Grants Completion Date: Review of process began in October 2024. Adjustments and revisions to initial processes will be made as needed, but will be completed by June 30, 2025.
FAC accepted this audit on December 5, 2023 — management decision was due June 5, 2024.
The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were followed. Questioned Costs: None. Context: The District was unable to provide any supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2023. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: The District experienced departmental turnover during fiscal year 2023. As there were no checklists or procedures manuals in place, employees within the responsible department were unaware of the internal controls in place over the Assessment System Security process they were required to follow. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Strategy and Data Acquisition Education Insights Department create a checklist or procedures manual to ensure that all required internal controls are completed. In addition, the District and Department should cross-train employees to allow for better continuity in the event of turnover. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Show full finding ▾Hide full finding ▴2023-002 Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010 - Title I Passed-through Colorado Department of Education Award Number - 4010, 5010, 7010; Award Year 2023 Criteria: According to 2 CFR Part 200.303 - The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were followed. Questioned Costs: None. Context: The District was unable to provide any supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2023. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: The District experienced departmental turnover during fiscal year 2023. As there were no checklists or procedures manuals in place, employees within the responsible department were unaware of the internal controls in place over the Assessment System Security process they were required to follow. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Strategy and Data Acquisition Education Insights Department create a checklist or procedures manual to ensure that all required internal controls are completed. In addition, the District and Department should cross-train employees to allow for better continuity in the event of turnover. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
2023-002 Finding: Assessment System Security Title 1, Section 1111(b)(2)(B)(iii) of the ESEA (20 USC 6311(b)(2)(B)(iii))) Summary of Finding: The District is required to establish internal controls to ensure assessment security. Historically one of these internal controls included a Site Visit Schedule to provide security assessment reviews. Site visits were performed at a select number of schools but did not include all Title schools in compliance with the requirements of the grant. Status: Corrective action in progress Client Planned Action: The District concurs with the recommendations and is currently implementing a process to ensure compliance. The Chief of Strategy and Data Acquisition has developed in coordination with the district Director of Metrics and Accountability, Area Superintendents, and the Colorado Department of Education Assessment Division a process processes to implement the needed internal controls that will ensure compliance to this requirement. They are as follows: Area Data Coaches will visit their portfolio of schools in the first 3 days of the state assessment window to ensure compliance with assessment security policies and procedures. Each data coach will receive full training from the CDE and the District Assessment Coordinator to ensure compliance with all security protocols in each building. Education Insights utilizes Area Data Coaches who work in close partnership with each Area Superintendent. Client Responsible Party: Natasha Crouse, Director of Metrics and Accountability. Each site visit will be documented with findings and any pertinent outcomes recorded. These logs will be securely stored on the Education Insights shared drive. Client Responsible Party: Dr. David Khaliqi, Chief of Strategy and Data Acquisition Completion Date: Assessment security training implemented as of March. 1, 2024. Standardized security assessment checklists and rubrics will be established by April 1, 2024. All site visits will be completed by April 10, 2024. Ongoing training throughout the year will be accomplished as needed. Adjustments and revisions to initial processes will be implemented as needed. Time and Effort certifications will be completed semi-annually.
FAC accepted this audit on November 22, 2022 — management decision was due May 22, 2023.
The District's internal control policy (DE-R-2) requires that the District complete semiannual time and effort certifications for employees with wages and/or benefits that are charged to a federal grant. We noted that no time and effort certifications were completed for fiscal year 2022. In addition, we noted that there were no internal control checklists or procedures manuals for the grants department staff to follow while administering the various grants of the District. Questioned Costs: None. Context: We tested 65 payroll and nonpayroll transactions for the grants identified above for the year ended June 30, 2022 and noted 17 instances in which time and effort certification was required and could not be provided. The tested population covered expenditures of $2.9 million and the total population of expenditures were approximately $11.9 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over the ESSER program, which could result in inaccurate or unallowable expenditures being applied against the grant. Cause: The District's grants department had 100% turnover during fiscal year 2022. As there were no checklists or procedures manuals in place, the new grants department staff were unaware of the internal controls in place over the ESSER program they were required to follow. In addition, the District's process to ensure that all required time and effort certifications are completed does not allow for timely recognition of uncompleted certifications.Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's grants department create a checklist or procedures manual to ensure that all required internal controls are completed. In addition, the District's grants department should work with other District departments to ensure they are aware of all internal control policies effecting grants. Finally, the District should cross-train employees to allow for better continuity in the event of turnover. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Show full finding ▾Hide full finding ▴2022-001 Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund Federal Assistance Listing Number 84.425U - COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief Federal Assistance Listing Number 84.425W - COVID-19 American Rescue Plan ? Elementary and Secondary School Emergency Relief ?Homeless Children and Youth Passed-through Colorado Department of Education Award Number - 4425, 5425, 4420, 4419, 4414, 9414, 4413, 8425, 9019; Award Year 2022 Criteria: According to 2 CFR Part 200.303 - The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District's internal control policy (DE-R-2) requires that the District complete semiannual time and effort certifications for employees with wages and/or benefits that are charged to a federal grant. We noted that no time and effort certifications were completed for fiscal year 2022. In addition, we noted that there were no internal control checklists or procedures manuals for the grants department staff to follow while administering the various grants of the District. Questioned Costs: None. Context: We tested 65 payroll and nonpayroll transactions for the grants identified above for the year ended June 30, 2022 and noted 17 instances in which time and effort certification was required and could not be provided. The tested population covered expenditures of $2.9 million and the total population of expenditures were approximately $11.9 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over the ESSER program, which could result in inaccurate or unallowable expenditures being applied against the grant. Cause: The District's grants department had 100% turnover during fiscal year 2022. As there were no checklists or procedures manuals in place, the new grants department staff were unaware of the internal controls in place over the ESSER program they were required to follow. In addition, the District's process to ensure that all required time and effort certifications are completed does not allow for timely recognition of uncompleted certifications.Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's grants department create a checklist or procedures manual to ensure that all required internal controls are completed. In addition, the District's grants department should work with other District departments to ensure they are aware of all internal control policies effecting grants. Finally, the District should cross-train employees to allow for better continuity in the event of turnover. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
2022-001 Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425D - COVID 19 Elementary and Secondary School Emergency Fund (ESSER) Federal Assistance Listing Number 84.425U - COVID 19 Elementary and Secondary School Emergency Fund (ESSER) Federal Assistance Listing Number 84.425W - COVID 19 Elementary and Secondary School Emergency Fund (ESSER)Homeless Children and Youth Passed-through Colorado Department of Education Award Number - 4425, 5425, 4420, 4419, 4414, 9414,4413, 8425, 9019; Award Year 2022 Summary of Finding: The District?s internal control policy requires that the district complete semi-annual time and effort certification for employees with wages and/or benefits that are charged to a federal grant. No time and effort certifications were completed for FY 2022. In addition, there were no internal controls checklists or procedure manuals for the grants department staff to follow while administering the various grants of the district. Status: Corrective action in progress Client Planned Action: The District concurs with the recommendations and is currently implementing a process to ensure compliance. Grants Dept. met with Area Superintendents and Program Directors to discuss the process and procedures to implement, and internal controls that would ensure this. They are as follows: Each department is responsible for collecting time and effort certification which will be signed by the staff member receiving the wages, and by a supervisor primarily responsible for collecting and verifying the documentation. Completion of time and effort forms are a joint responsibility between the employee and the supervisor and will be verified by the Grants Department. Internal controls are being put into place to ensure that processes are implemented regardless of possible staff turnover. Grants Staff have access to updated electronic files, housed in the S Drive, to ensure accessibility. These files contain detailed procedures and processes for the tasks that staff is required to complete. Client Responsible Party: Annette Bass, Director of Grants Completion Date: Internal Controls and training implemented as of Nov. 1, 2022. Training ongoing throughout the year as needed. Adjustments and revisions to initial processes as needed. Time and Effort certifications will be completed semi-annually.
The District did not obtain certified payrolls for contractor or subcontractor work performed during the fiscal year ended June 30, 2022. In addition, the District did not have internal controls in place to identify that certified payrolls were not obtained. Questioned Costs: Unknown. Context: There was one construction project charged to the grant during the year. We tested the one contractor and six subcontractor assigned to this project and noted the following: - The District did not obtain any certified payrolls for the contractor and subcontractors tested. - One of the subcontractor agreements did not include the required wage requirement clauses within the subcontract. - The District did not have a process in place to track certified payrolls received and to compare them to prevailing wage rates. Effect: Certified Payrolls were not obtained or reviewed for the project so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Cause: The District was unaware of the wage rate requirements as it applied to this grant and as such, there was no assigned department or employee to monitor, review and obtain certified payrolls during the year from contractors and subcontractors. Identification as a Repeat Finding: Not applicable.Recommendation: We recommend the District implement internal controls over wage rate requirements, including facilities staff on-site weekly where projects are occurring to determine if work was completed towards the project, tracking certified payrolls or notification of no work performed and reviewing to help ensure wages are equal to or in excess of the prevailing wage rates. Views of Responsible Officials: Agree. See separate report for planned corrective actions.
Show full finding ▾Hide full finding ▴2022-002 Finding: Special Tests - Wage Rate Requirements Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund (ESSER) Passed-through Colorado Department of Education Award Number - 4420; Award Year 2022 Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Non-Federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the Non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The District did not obtain certified payrolls for contractor or subcontractor work performed during the fiscal year ended June 30, 2022. In addition, the District did not have internal controls in place to identify that certified payrolls were not obtained. Questioned Costs: Unknown. Context: There was one construction project charged to the grant during the year. We tested the one contractor and six subcontractor assigned to this project and noted the following: - The District did not obtain any certified payrolls for the contractor and subcontractors tested. - One of the subcontractor agreements did not include the required wage requirement clauses within the subcontract. - The District did not have a process in place to track certified payrolls received and to compare them to prevailing wage rates. Effect: Certified Payrolls were not obtained or reviewed for the project so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Cause: The District was unaware of the wage rate requirements as it applied to this grant and as such, there was no assigned department or employee to monitor, review and obtain certified payrolls during the year from contractors and subcontractors. Identification as a Repeat Finding: Not applicable.Recommendation: We recommend the District implement internal controls over wage rate requirements, including facilities staff on-site weekly where projects are occurring to determine if work was completed towards the project, tracking certified payrolls or notification of no work performed and reviewing to help ensure wages are equal to or in excess of the prevailing wage rates. Views of Responsible Officials: Agree. See separate report for planned corrective actions.
2022-002 Finding: Special Tests - Wage Rate Requirements Federal Assistance Listing Number 84.425D - COVID 19 Elementary and Secondary School Emergency Fund (ESSER) Passed-through Colorado Department of Education Award Number - 4420; Award Year 2022 Summary of Finding: The District did not obtain certified payrolls for contractor or subcontractor work performed. The District did not have internal controls in place to identify that certified payrolls were not obtained. Status: Corrective action in progress Client Planned Action: The District concurs with the recommendations and is currently developing and implementing internal controls to ensure compliance. Grants Department personnel met with Facilities personnel to discuss the processes and procedures to implement, and internal controls that would ensure this. These will include a monthly checklist, verified with signatures of Facilities and Grants Department Personnel. This checklist will provide verification that certified payroll is being monitored and reviewed weekly, and is being compared to prevailing wage rates. Client Responsible Party: Annette Bass, Director of Grants Completion Date: Initial implementation of internal controls beginning on August 1. Adjustments and revisions to initial processes as needed. The verifications are to be done on a recurring monthly basis.
FAC accepted this audit on November 16, 2021 — management decision was due May 16, 2022.
We noted that Colorado Springs School District 11 incorrectly applied a portion of the increased cost unemployment insurance for two of the four quarters of fiscal year 2021. Questioned Costs: $230,847. Questioned costs were determined by isolating unemployment insurance charges paid in excess of the required invoice amount which were applied to the grant. Context: We tested 40 payroll and nonpayroll transactions for the ESSER I grant for the year ended June 30, 2021 and noted two instances out of 40 in which a portion of the unemployment insurance costs were improperly charged towards the grant. The tested population covered expenditures of $5.4 million and the total population of expenditures were approximately $8.1 million. A non-statistical sampling methodology was used to select the sample. Effect: The District paid in excess of the required unemployment insurance invoice amount an thus overd -char ged the grant. Cause: As a result of COVID, the Colorado Department of Labor and Employment reduced the amount of unemployment insurance which districts were required to pay. While the invoices did not include the amount before the reduction, the invoice clearly identified the required amount due. The District controls over accounts payable and review of expenditures applied against federal grants did not identify that the District had paid in excess of the required unemployment insurance invoice amount for two quarters of fiscal year 2021. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that the District work with the Colorado Department of Labor and Employment to obtain a credit or refund on the amount paid in excess of the required invoice amount. In addition, we recommend that the District strengthen the internal controls surrounding review of expenditures applied against federal grants. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions .
Show full finding ▾Hide full finding ▴Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Relief Fund (ESSER) Department of Education, Passed-through Colorado Department of Education Award Number - 4425; Award Year 2021 Criteria: According to 2 CFR Part 200.403 factors affecting allowability of costs - costs must meet the following general criteria in order to be allowable under federal awards: (a) be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles, (b) conform to any limitations or exclusions set forth in these principles or in the federal award as to types or amount of cost items, (c) be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-federal entity, (d) be accorded consistent treatment, (e) be determined in accordance with generally accepted accounting principles, (f) to be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period and (g) be adequately documented. Condition: We noted that Colorado Springs School District 11 incorrectly applied a portion of the increased cost unemployment insurance for two of the four quarters of fiscal year 2021. Questioned Costs: $230,847. Questioned costs were determined by isolating unemployment insurance charges paid in excess of the required invoice amount which were applied to the grant. Context: We tested 40 payroll and nonpayroll transactions for the ESSER I grant for the year ended June 30, 2021 and noted two instances out of 40 in which a portion of the unemployment insurance costs were improperly charged towards the grant. The tested population covered expenditures of $5.4 million and the total population of expenditures were approximately $8.1 million. A non-statistical sampling methodology was used to select the sample. Effect: The District paid in excess of the required unemployment insurance invoice amount an thus overd -char ged the grant. Cause: As a result of COVID, the Colorado Department of Labor and Employment reduced the amount of unemployment insurance which districts were required to pay. While the invoices did not include the amount before the reduction, the invoice clearly identified the required amount due. The District controls over accounts payable and review of expenditures applied against federal grants did not identify that the District had paid in excess of the required unemployment insurance invoice amount for two quarters of fiscal year 2021. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that the District work with the Colorado Department of Labor and Employment to obtain a credit or refund on the amount paid in excess of the required invoice amount. In addition, we recommend that the District strengthen the internal controls surrounding review of expenditures applied against federal grants. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions .
2021-001 Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425 D - COVID-19 Elementary and Secondary School Emergency Relief Fund (ESSER) Department of Education, Passed through Colorado Department of Education Award Number - 4425; Award Year 2021 STATUS: Corrective action in progress CLIENT PLANNED ACTION: The District concurs with the recommendations and currently has a project in-process working with the Colorado Department of Labor and Employment to obtain a credit or refund on the amount paid in excess of the required invoice amount. The project scope includes strengthening the internal controls surrounding review of expenditures applied against federal grants and increasing training for staff members. CLIENT RESPONSIBLE PARTY: Dr. Kristin Watkins, Director of Grants COMPLETION DATE: The phases of the project related to working with the Colorado Department of Labor and Employment is expected to be completed by December 30, 2021. The adjustment to internal controls and training protocols is complete as of 10/15/2021.
Documentation to support compliance with the above requirement was not available in all instances as described below: - One instance in which documentation could not be provided to support that the District checked to ensure the vendor was not federally suspended or debarred. - One instance in which documentation could not be provided to support that the District obtained price or rate quotations prior to entering into the procurement contract. Questioned Costs: None. Context: We tested three procurement contracts within the Child Nutrition Program Cluster for the year ended June 30, 2021 and noted the above conditions. The tested population covered procurements contracts of $255,000 and the total population of procurement contracts was approximately $4.7 million. A non-statistical sampling methodology was used to select the sample. Effect: By not maintaining documentation of federal suspension and debarment checks and quotations, the District is unable to substantiate the selection of the vendor for the procurement contract. Cause: The District did not follow its own internal controls, policies and procedures related to document retention. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that District perform a detailed review of existing policies and procedures in place to help ensure that all supporting documentation related to procurement contracting is retained by both the Food Nutrition Services and Procurement and Contracting Departments. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions .
Show full finding ▾Hide full finding ▴Finding: Procurement and Suspension and Debarment Federal Assistance Listing Number 10.579 - CCNP School Meals Equipment Federal Assistance Listing Number 10.555 - COVID 19-National School Lunch Program Federal Assistance Listing Number 10.559 - Summer Lunch Program Department of Agriculture, Passed-through Colorado Department of Education Award Number - 5579, 4555, 4559; Award Year 2021 Criteria: According to 200.320(2)(i) Methods of procurement - for the acquisition of property or services, which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold, small purchase procedures are used. Under small purchase procedures, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-federal entity. In addition, suspension and debarment standards outlined in 2 CFR 200.214 restrict a non-federal entity from entering into contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition: Documentation to support compliance with the above requirement was not available in all instances as described below: - One instance in which documentation could not be provided to support that the District checked to ensure the vendor was not federally suspended or debarred. - One instance in which documentation could not be provided to support that the District obtained price or rate quotations prior to entering into the procurement contract. Questioned Costs: None. Context: We tested three procurement contracts within the Child Nutrition Program Cluster for the year ended June 30, 2021 and noted the above conditions. The tested population covered procurements contracts of $255,000 and the total population of procurement contracts was approximately $4.7 million. A non-statistical sampling methodology was used to select the sample. Effect: By not maintaining documentation of federal suspension and debarment checks and quotations, the District is unable to substantiate the selection of the vendor for the procurement contract. Cause: The District did not follow its own internal controls, policies and procedures related to document retention. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that District perform a detailed review of existing policies and procedures in place to help ensure that all supporting documentation related to procurement contracting is retained by both the Food Nutrition Services and Procurement and Contracting Departments. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions .
2021-002 Finding: Procurement Federal Assistance Listing Number 10.579 - CCNP School Meals Equipment Federal Assistance Listing Number 10.555 - COVID 19-National School Lunch Program Federal Assistance Listing Number 10.559 - Summer Lunch Program Department of Agriculture, Passed-through Colorado Department of Education Award Number - 5579, 4555, 4559; Award Year 2021 STATUS: Corrective action in progress CLIENT PLANNED ACTION: The District FNS staff will continue to follow federal Office of School Nutrition (OSN) purchasing rules as offered via Colorado CDE guidelines. FNS will continue to obtain pricing quote for small purchases up to the Simplified Acquisition Threshold of $250,000 and seek acceptable sources in order for Procurement to establish Blanket Purchase Agreements and Issue corresponding purchase orders. Procurement will not issue any purchase order without receiving a minimum of three informal price quotes as required by OSN rules from FNS. Procurement will check the US SAMS website for Excluded Parties prior to issuing the purchase order. To ensure documentation is not misplaced/misfiled, a checklist for each FNS small purchases will have an in-house checklist to be followed before issuing the purchase order. Separately, Procurement will add a new FNS section to the District Acquisition Regulation. This will direct all FNS purchases must follow federal Office of School Nutrition purchasing guidelines found on the Colorado CDE website: https://www.cde.state.co.us/nutrition/procurementmethodsofprocurement FNS agrees with the recommendations and currently has a project in-process to draft and implement updated procedures for procurement in child nutrition. The scope includes establishing current procurement needs in child nutrition, as well as relevant thresholds, authorities, and processes going forward. All relevant FNS employees will attend yearly trainings on procurement. All food purchases exceeding $10,000 to a maximum of $250,000 will warrant documented price comparisons and debarment documentation, following CDE?s Small Purchase Checklist. Purchases exceeding $250,000 will warrant a formal request for proposal through the Procurement office. Client Responsible Party: FNS and Procurement Completion Date: Check lists and DAR updated to be completed within 30 days and training will be on-going throughout the year.
FAC accepted this audit on February 17, 2021 — management decision was due August 17, 2021.
FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.
The District's internal control policy is to maintain monthly or semi-annual time and effort certifications for those employees who have compensation applied to a federal grant. Certain salary and wages charged to the grant were not supported by monthly or semi-annual time and effort certifications. Questioned Costs: Title I - $2,566; Special Education Cluster $22,926; Supporting Effective Instruction $11,165. Questioned costs were determined by reviewing the fiscal year 2019 payments that occurred for the periods effected by the above issues. Context: We tested 122 payroll and nonpayroll transactions for the grants identified above for the year ended June 30, 2019 and noted the following: Title I: Three instances out of 42 in which time and effort certification could not be provided. The tested population covered expenditures of $595,000 and the total population of expenditures were approximately $7.8 million. Special Education Cluster: Seven instances out of 40 in which time and effort certification could not be provided. The tested population covered expenditures of $263,000 and the total population of expenditures were approximately $5.5 million. Supporting Effective Instruction: Two instances out of 40 in which time and effort certification could not be provided. The tested population covered expenditures of $446,000 and the total population of expenditures were approximately $0.9 million. A non-statistical sampling methodology was used to select the sample. Effect: Salary and wage costs were not fully supported by documentation in accordance with 2 Part 200.430 and District policy. Cause: The District's process to identify employees that require a periodic time and effort certification was not effective for the entire year ended June 30, 2019. In addition, the District's process to ensure that all required time and effort certifications are completed does not allow for timely recognition of uncompleted certifications. Identification as a repeat finding: Not Applicable Recommendation: During fiscal year 2020 the District started a process to implement procedures to strengthen controls and improve procedures for timely follow-up. We recommend the District continue this process to strengthen controls and to ensure all required certifications are obtained. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Show full finding ▾Hide full finding ▴Finding: Allowable Costs/Cost Principles CFDA No. 84.010 - Title I Grants to Local Educational Agencies Special Education Cluster (IDEA) CFDA No. 84.027 - Special Education - Grants to States (IDEA, Part B) CFDA No. 84.173 - Special Education - Preschool Grants (IDEA Preschool) CFDA No. 84.367 - Supporting Effective Instructions State Grants U.S. Department of Education, Passed through the Colorado Department of Education, Award Numbers: 4010, 5010, 7010, 4367, 4027 and 4173, Award Year 2019 Criteria: According to 2 Part 200.430 Compensation - Personal Services dictates that costs of compensation are allowable if the services rendered are reasonable and conforms to the established written policy of the non-federal entity. In addition, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-federal entity; (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: The District's internal control policy is to maintain monthly or semi-annual time and effort certifications for those employees who have compensation applied to a federal grant. Certain salary and wages charged to the grant were not supported by monthly or semi-annual time and effort certifications. Questioned Costs: Title I - $2,566; Special Education Cluster $22,926; Supporting Effective Instruction $11,165. Questioned costs were determined by reviewing the fiscal year 2019 payments that occurred for the periods effected by the above issues. Context: We tested 122 payroll and nonpayroll transactions for the grants identified above for the year ended June 30, 2019 and noted the following: Title I: Three instances out of 42 in which time and effort certification could not be provided. The tested population covered expenditures of $595,000 and the total population of expenditures were approximately $7.8 million. Special Education Cluster: Seven instances out of 40 in which time and effort certification could not be provided. The tested population covered expenditures of $263,000 and the total population of expenditures were approximately $5.5 million. Supporting Effective Instruction: Two instances out of 40 in which time and effort certification could not be provided. The tested population covered expenditures of $446,000 and the total population of expenditures were approximately $0.9 million. A non-statistical sampling methodology was used to select the sample. Effect: Salary and wage costs were not fully supported by documentation in accordance with 2 Part 200.430 and District policy. Cause: The District's process to identify employees that require a periodic time and effort certification was not effective for the entire year ended June 30, 2019. In addition, the District's process to ensure that all required time and effort certifications are completed does not allow for timely recognition of uncompleted certifications. Identification as a repeat finding: Not Applicable Recommendation: During fiscal year 2020 the District started a process to implement procedures to strengthen controls and improve procedures for timely follow-up. We recommend the District continue this process to strengthen controls and to ensure all required certifications are obtained. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
2019 ? 001 Allowable Costs/Cost Principles Finding cause: The district?s process to identify employees that require a periodic time and effort certification was not effective for the year ended June 30, 2019. In addition, the district?s process to ensure that all required time and effort certifications are completed does not allow for timely recognition of uncompleted certifications. Condition: The district?s internal control policy is to maintain monthly or semi-annual time and effort certifications for those employees who have compensation applied to a federal grant. Certain salary and wages charged to the grant were not supported by monthly or semi-annual time and effort certifications. The district identified two causes for the instances identified. 1) A staff member primarily responsible for collecting and verifying the time and effort documentation made errors in reconciling the documentation to the grant-funded staffing list which caused missing certifications in some instances. 2) A staff vacancy in another department led to a gap in collection of certifications. Status: The district has started a process to implement procedures to strengthen controls and improve procedures for timely follow-up as recommended by the auditor. The district will continue this process to strengthen controls and ensure all required certifications are obtained. The district?s corrective process includes: 1) Each department responsible for collecting time and effort certification will assign a second staff member to the task whose responsibility will be to conduct a second reconciliation against a grant-funded staffing list provided by the Human Resources Department to ensure all grant-funded staff (managed by said department) are included and related certifications are collected. This two-deep verification process also will help to minimize the potential for missed documentation collection due to staff transitions/vacancies. 2) The district?s Grants Department will: a. Require all departments/teams managing federally funded grants with salary expenditures to designate annually the two staff members responsible for time and effort certifications. b. Request quarterly and / or semi-annual written confirmation (as appropriate) that responsible staff have reviewed/reconciled collected documentation to Human Resources Department lists for each grant. Person responsible for implementation: Patricia Reitwiesner Implementation Date: October 21, 2019
FAC accepted this audit on December 4, 2018 — management decision was due June 4, 2019.
FAC accepted this audit on November 14, 2017 — management decision was due May 14, 2018.
FAC accepted this audit on November 20, 2016 — management decision was due May 20, 2017.
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