MINERAL COUNTY SCHOOL DISTRICT

C. Findings and Questioned Costs - Major Federal Award Programs Department of Education Questioned Costs 2022-007 Federal Financial Reporting None Significant Deficiency Criteria: Management is responsible for establishing and maintaining an effective system of internal control over financial reporting. One of the components of an effective system of internal control over financial reporting is the subsequent review and approval of grant reporting to grantor agencies. Condition: The District did not have supporting documentation that indicated reporting of federal grant expenditures were reviewed and approved by management. Effect of Condition: It is possible that errors in financial grant reporting could occur and not be prevented or detected. Cause of Condition: Due to turnover, the District was operating without a finance director for the period March through July. Recommendation: We recommend that District implement procedures that establish that all federal grant reports be reviewed and approved by management. Management Response and Corrective Action Plan: Management recognizes that there is an inherent and elevated risk associated with vacancies in key positions and inexperienced key personnel in certain positions. At present, all key positions are filled, and personnel are fully participating in NDE sponsored projects including program compliance monitoring, technical assistance support and evaluation studies as required. Two of the District?s Top Priorities are recruiting, retaining, and training (including cross-training in basic duties) essential personnel and updating policies, procedures and ARs to ensure internal controls and fiscal responsibility.

2021-001 CARES Act ? ESSER 84.425D Unknown Significant Deficiency Condition: A schoolwide program school that does not consolidate Federal funds in a consolidated schoolwide pool must maintain separate records by program. The District failed to obtain adequate time and effort supporting documentation over those employees assigned to both federal and non-federal programs. Criteria: CRF section 200.431(i)(1)(Vii) requires the District to maintain time and effort distribution records that support the portion of time and effort dedicated to each program or other cost objectives which are supported by federal and non-federal funds. Effect of Condition: Without the required appropriate time and effort personnel activity records, grant personnel costs could be disallowed by the grantor agencies. Cause of Condition: District personnel assigned to enforcing and maintaining adequate supporting documentation over federal grant time certifications and time and efforts records failed to enforce District policy over such records. Recommendation: All district personnel with grant oversight responsibility should have a systematic review of required compliance cost principles. All grant personnel and supervisors need to be advised of their responsibility to assure grant compliance. Management Response and Corrective Action Plan: District supervisory personnel were aware of the requirement to document actual time worked on grant eligible activities. On several occasions, time and effort requirements were brought to the attention of personnel assigned this duty. However, appropriate documentation was not timely obtained. The District has mandated that all grant employees and supervisors receive appropriate training and tools necessary to adhere in maintaining appropriate activity records.

2021-002 Coronavirus Relief Funding 21.109 Unknown CARES Act ? ESSER 84.425D Significant Deficiency Condition: The District received several grants which provided for the purchase of Chromebooks to assist with student distant learning due to Covid-19 pandemic protocols. It was reported the District failed to adequately track the distribution of these Chromebooks. Criteria: 2 CRF section 200.313(d)(3) requires the District to develop a control system to ensure adequate safeguards preventing the loss, damage or theft of property. Effect of Condition: Without adequate safeguards in place, equipment including technological equipment could be lost or stolen without timely detection. Cause of Condition: The District does not have an adequate property management program in place to track technological equipment once received for distribution to school sites. Recommendation: We recommend the District develop an adequate property management program over equipment (including technological equipment) that will trace and track such equipment once received. Management Response and Corrective Action Plan: Management concurs with the demonstrated need for a robust inventory control system. The current process of manual tracking has resulted in a fragmented inventory that is cumbersome to navigate and articulate. During the audit process, Mineral County School District invested in an electronic inventory system that interfaces with Infinite Visions. The implementation should be completed by the end of December 2021.

Title 1. Part A Basic Education - 84.010 Condition: A schoolwide program school that does not consolidate Federal funds in a consolidated schoolwide pool must maintain separate records by program. The District failed to obtain adequate time and effort supporting documentation over those employees assigned to both federal and non-federal programs. Criteria: CRF section 200.431(i)(1)(Vii) requires the District to maintain time and effort distribution records that support the portion of time and effort dedicated to each program or other cost objectives which are supported by federal and non-federal funds. Effect of Condition: Without the required appropriate time and effort personnel activity records, grant personnel costs could be disallowed by the grantor agencies. Cause of Condition: District personnel assigned to enforcing and maintaining adequate supporting documentation over federal grant time certifications and time and efforts records failed to enforce District policy over such records. Recommendation: All district personnel with grant oversight responsibility should have a systematic review of required compliance cost principles. All grant personnel and supervisors need to be advised of their responsibility to assure grant compliance. Management Response and Corrective Action Plan: District supervisory personnel were aware of the requirement to document actual time worked on grant eligible activities. On several occasions, the time and effort requirement was brought to the attention of grant personnel assigned this duty. However, appropriate documentation was not timely obtained. The District has mandated that all grant employees and supervisors receive appropriate training and tools necessary to adhere in maintaining appropriate activity records.

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