OSBORN ELEMENTARY SCHOOL DISTRICT NO. 8

REFERENCE: 2022-101 CFDA NUMBER: 84.027A ? SPECIAL EDUCATION ? GRANTS TO STATES CFDA NUMBER: 84.027X ? SPECIAL EDUCATION ? GRANTS TO STATES CFDA NUMBER: 84.173A ? SPECIAL EDUCATION ? PRESCHOOL GRANTS U.S. DEPARTMENT OF EDUCATION ? 2022 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBERS: H027A210007, H027X210007, H173A210003 QUESTIONED COSTS N/A CONDITION The following errors were noted during the review of 40 special education student files: 1. For 5 of 40 files tested, the Individualized education program (IEP) was not completed timely. The IEPs were between 1 and 54 days late. 2. For 3 of 40 files tested, the primary disability category was not properly reported. A prior or secondary eligibility category was used rather than the current primary eligibility category. 3. Although the District has established internal control processes and procedures to ensure student files include required documentation, the performance of these control activities was not documented for 1 of 40 provider files tested. All children were provided appropriate services timely and the errors had no effect on funding amounts. CRITERIA In accordance with 34 CFR 300.323 (c)(1), a meeting to develop an IEP for a child is conducted within 30 days of a determination that the child needs special education and related services. In accordance with 34 CFR 300.324 (b) Review and revision of IEPs ? (1) General, each public agency must ensure that, subject to paragraphs (b)(2) and (b)(3) of this section, the IEP Team ? (i) Reviews the child's IEP periodically, but not less than annually, to determine whether the annual goals for the child are being achieved. In accordance with 2 CFR 200.61, internal controls means a process, implemented by a non-Federal entity, designed to provide reasonable assurance regarding the achievement of objectives in the following categories: (a) Effectiveness and efficiency of operations; (b) Reliability of reporting for internal and external use; and(c) Compliance with applicable laws and regulations. EFFECT Federal program requirements were not complied with. IEP and reevaluations were not completed timely. CAUSE Although the internal controls were adequately designed, there were deficiencies in the execution of the controls. RECOMMENDATION AND BENEFIT A process should be developed to ensure that IEPs are completed timely and disability categories are properly reported. Additionally, control activities to ensure provider student files include required documentation should be documented. This will help ensure that federal program requirements are complied with and IEPs and reevaluations are completed timely. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

REFERENCE: 2021-101 CFDA NUMBER 10.555 ? NATIONAL SCHOOL LUNCH PROGRAM CFDA NUMBER 10.559 ? SUMMER FOOD SERVICE PROGRAM FOR CHILDREN U.S. DEPARTMENT OF AGRICULTURE - 2021 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION QUESTIONED COSTS N/A CONDITION The following deficiencies were noted while testing reimbursement claims for September 2020, April 2021 and June 2021: 1. Summary sheets for April and June 2021 did not agree to the ADE Summer Food Service Program Daily Meal Count Forms. This resulted in an overreporting of 24 Breakfasts and 6 Afternoon Snacks and an underreporting of 22 Lunches. 2. Summary sheets re-created for September 2020 had the following errors: a. The summary sheets did not agree to the district wide Site Meal Service Summary submitted to ADE. This resulted in an overreporting of 433 Breakfasts and 298 Lunches. b. The summary sheets did not agree to supporting ADE Summer Food Service Program Daily Meal Count Forms, manual route sheets for deliveries or other supporting documentation. This resulted in an overreporting of 432 Breakfasts and 432 Lunches. These variances resulted in an over payment (known questioned costs) of $5,056. However, after projecting the various types of errors over three meal categories for the entire year, likely questioned costs totaled $3,787. CRITERIA In accordance with 7 CFR 210.8(a)(2) Prior to the submission of a monthly Claim for Reimbursement, each school food authority shall review the lunch count data for each school under its jurisdiction to ensure the accuracy of the monthly Claim for Reimbursement. The objective of this review is to ensure that monthly claims include only the number of free, reduced price and paid lunches served on any day of operation to children currently eligible for such lunches. In accordance with 7 CFR 225.9(d)(5) Claims for reimbursement shall report information in accordance with the financial management system established by the State agency, and in sufficient detail to justify the reimbursement claimed and to enable the State agency to provide the Reports of Summer Food Service Program Operations required under ? 225.8(b). In submitting a claim for reimbursement, each sponsor shall certify that the claim is correct and that records are available to support this claim. Failure to maintain such records may be grounds for denial of reimbursement for meals claimed during the period covered by the records in question. The costs of meals to adults performing necessary food service labor may be included in the claim. Under no circumstances may a sponsor claim the cost of any disallowed meals as operating costs. In accordance with the Uniform Guidance, Compliance Supplement, Part 6 ? Internal Control, the 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. EFFECT Program requirements were not complied with. The reimbursement claims were not properly reviewed for supporting documentation and the District was over paid for meals served. CAUSE Changes within the National School Lunch and the Summer Food Service Programs in response to the COVID-19 pandemic required the District to change methods of documentation for meals served. The method used to track meals in August and September 2020 was changed in October 2020. Additionally, various forms of documentation were not always retained to support the number of meals served. RECOMMENDATION AND BENEFIT Reimbursement claims should be compared to supporting documentation and reviewed for accuracy prior to submission to the Arizona Department of Education. A second employee not responsible for the preparation of the reimbursement claims should perform the review. Additionally, the review should be documented. This will help ensure that program requirements are complied with and the reimbursement claims are accurately completed and the District is not over or under paid for meals served. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

OSBORN ELEMENTARY SCHOOL DISTRICT NO. 8 SCHEDULE OF FINDINGS AND QUESTIONED COSTS SECTION 3 - FINDINGS AND QUESTIONED COSTS FOR FEDERAL AWARDS JUNE 30, 2019 REFERENCE: 2019-101 CFDA NUMBER: 84.027 ? SPECIAL EDUCATION ? GRANTS TO STATES CFDA NUMBER: 84.173 ? SPECIAL EDUCATION ? PRESCHOOL GRANTS U.S. DEPARTMENT OF EDUCATION ? 2019 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBERS: H027A140007, H173A140003 QUESTIONED COSTS N/A CONDITION The following errors were noted during the review of 40 special education student files: 1. For 8 of 40 files tested, the Individualized education program (IEP) was not completed timely. The IEPs were between 2 and 147 days late. 2. For 1 of 40 files tested, the IEP was not completed within 30 days of the determination that the child was in need special education and related services. 3. For 2 of 40 files tested, the reevaluation was not completed timely. The reevaluations were between 28 and 82 days late. 4. Although the District has established internal control processes and procedures to ensure student files include required documentation, the performance of these control activities was not documented for 2 of 40 provider files tested. All children were provided appropriate services timely and the errors had no effect on funding amounts. CRITERIA In accordance with 34 CFR 300.323 (c)(1), a meeting to develop an IEP for a child is conducted within 30 days of a determination that the child needs special education and related services. In accordance with 34 CFR 300.324 (b) Review and revision of IEPs ? (1) General, each public agency must ensure that, subject to paragraphs (b)(2) and (b)(3) of this section, the IEP Team ? (i) Reviews the child's IEP periodically, but not less than annually, to determine whether the annual goals for the child are being achieved. In accordance with 34 CFR 300.303 (b) Limitation, a reevaluation conducted under paragraph (a) of this section ? (1) May occur not more than once a year, unless the parent and the public agency agree otherwise; and (2) Must occur at least once every 3 years, unless the parent and the public agency agree that a reevaluation is unnecessary. In accordance with 2 CFR 200.61, internal controls means a process, implemented by a non-Federal entity, designed to provide reasonable assurance regarding the achievement of objectives in the following categories: (a) Effectiveness and efficiency of operations; (b) Reliability of reporting for internal and external use; and(c) Compliance with applicable laws and regulations. EFFECT Federal program requirements were not complied with. IEP and reevaluations were not completed timely. CAUSE Although the internal controls were adequately designed, there were deficiencies in the execution of the controls. RECOMMENDATION AND BENEFIT A process should be developed to ensure that IEPs and reevaluations are completed timely. Additionally, control activities to ensure provider student files include required documentation should be documented. This will help ensure that federal program requirements are complied with and IEPs and reevaluations are completed timely. (concluded)

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