EIN: 916001546
UEI: KNQKL9KQBNJ7
Audited by: Office of the Washington State Auditor
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 April 30, 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 October 30, 2026 (60 days from today).
What is a management decision? →2025-001 The District did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Assistance Listing Number and Title: 10.553 – School Breakfast Program 10.555 – National School Lunch Program 10.559 – Summer Food Service Program for Children 10.582 – Fresh Fruit and Vegetable Program Federal Agency Name: U.S. Department of Agriculture (USDA) Federal Award/Contract Number: N/A 2025-001 The District did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Assistance Listing Number and Title: 10.553 – School Breakfast Program 10.555 – National School Lunch Program 10.559 – Summer Food Service Program for Children 10.582 – Fresh Fruit and Vegetable Program Federal Agency Name: U.S. Department of Agriculture (USDA) Federal Award/Contract Number: N/A Pass-through Entity Name: Office of the Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: 257WAWA3N1199 257WAWA3N1603 Known Questioned Cost Amount: $0 Prior Year Audit Finding: N/A Background The District participates in the Child Nutrition Cluster, which includes the School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children and Fresh Fruits and Vegetable Program. These programs provide free and reduced-price meals to students from low-income families. The District received $2,311,018 to administer these programs during the 2024-25 school year. Federal regulations require recipients to establish, document and maintain effective internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. Federal requirements prohibit recipients from contracting with or purchasing from parties suspended or debarred from doing business with the federal government. Whenever the District enters into contracts or purchases goods and services that it expects to equal or exceed $25,000, paid all or in part with federal funds, it must verify the contractors are not suspended, debarred or otherwise excluded from participating in federal programs. The District may verify this by obtaining a written certification from the contractor, adding a clause or condition into the contract that states the contractor is not suspended or debarred, or checking for exclusion records in the U.S. General Services Administration’s System for Award Management at SAM.gov. The District must verify this before entering into the contract, and must maintain documentation demonstrating compliance with this federal requirement. Description of Condition Although the District has a process to verify the suspension and debarment status for contractors it pays more than $25,000, our audit found the District did not follow this process and did not verify four of the five contractors we tested were not suspended or debarred before purchasing from them. The District selected these contractors from a purchasing cooperative and did not establish a process to retain documentation of the cooperative’s verification of the contractors’ suspension and debarment status. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. Cause of Condition District staff were aware of the federal suspension and debarment verification requirements and said they reviewed the cooperative’s suspension and debarment certifications for the contractors. However, staff did not realize they needed to retain this documentation showing the contractors were not suspended or debarred before purchasing from them. Effect of Condition The District did not obtain a written certification from the contractors, insert a clause into the contracts or check for exclusion records at SAM.gov to verify contractors it paid $895,703 with federal funds were not suspended or debarred before contracting. Further, the District did not retain documentation showing the purchasing cooperative verified the contractors’ suspension and debarment status before purchasing. Without adequate internal controls, the District increases its risk of awarding federal funds to contractors that are excluded from participating in federal programs. Any payments the District made to an ineligible party would be unallowable, and the awarding agency could potentially recover them. We subsequently verified the contractors were not suspended or debarred. Therefore, we are not questioning costs. Recommendation We recommend the District strengthen its internal controls to verify all contractors it pays $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs and maintain documentation demonstrating compliance with this requirement. District’s Response The cooperative provides all bid documents for the district representatives to review, this included suspension and debarment documentation. After review at a meeting of the cooperative membership, the members vote on accepting the bid. The cooperative keeps all documentation on file for review of the auditors. Documentation of this was provided to the auditor. Auditor’s Remarks We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District’s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 180, OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement), establishes nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689.
Show full finding ▾Hide full finding ▴2025-001 The District did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Assistance Listing Number and Title: 10.553 – School Breakfast Program 10.555 – National School Lunch Program 10.559 – Summer Food Service Program for Children 10.582 – Fresh Fruit and Vegetable Program Federal Agency Name: U.S. Department of Agriculture (USDA) Federal Award/Contract Number: N/A 2025-001 The District did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Assistance Listing Number and Title: 10.553 – School Breakfast Program 10.555 – National School Lunch Program 10.559 – Summer Food Service Program for Children 10.582 – Fresh Fruit and Vegetable Program Federal Agency Name: U.S. Department of Agriculture (USDA) Federal Award/Contract Number: N/A Pass-through Entity Name: Office of the Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: 257WAWA3N1199 257WAWA3N1603 Known Questioned Cost Amount: $0 Prior Year Audit Finding: N/A Background The District participates in the Child Nutrition Cluster, which includes the School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children and Fresh Fruits and Vegetable Program. These programs provide free and reduced-price meals to students from low-income families. The District received $2,311,018 to administer these programs during the 2024-25 school year. Federal regulations require recipients to establish, document and maintain effective internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. Federal requirements prohibit recipients from contracting with or purchasing from parties suspended or debarred from doing business with the federal government. Whenever the District enters into contracts or purchases goods and services that it expects to equal or exceed $25,000, paid all or in part with federal funds, it must verify the contractors are not suspended, debarred or otherwise excluded from participating in federal programs. The District may verify this by obtaining a written certification from the contractor, adding a clause or condition into the contract that states the contractor is not suspended or debarred, or checking for exclusion records in the U.S. General Services Administration’s System for Award Management at SAM.gov. The District must verify this before entering into the contract, and must maintain documentation demonstrating compliance with this federal requirement. Description of Condition Although the District has a process to verify the suspension and debarment status for contractors it pays more than $25,000, our audit found the District did not follow this process and did not verify four of the five contractors we tested were not suspended or debarred before purchasing from them. The District selected these contractors from a purchasing cooperative and did not establish a process to retain documentation of the cooperative’s verification of the contractors’ suspension and debarment status. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. Cause of Condition District staff were aware of the federal suspension and debarment verification requirements and said they reviewed the cooperative’s suspension and debarment certifications for the contractors. However, staff did not realize they needed to retain this documentation showing the contractors were not suspended or debarred before purchasing from them. Effect of Condition The District did not obtain a written certification from the contractors, insert a clause into the contracts or check for exclusion records at SAM.gov to verify contractors it paid $895,703 with federal funds were not suspended or debarred before contracting. Further, the District did not retain documentation showing the purchasing cooperative verified the contractors’ suspension and debarment status before purchasing. Without adequate internal controls, the District increases its risk of awarding federal funds to contractors that are excluded from participating in federal programs. Any payments the District made to an ineligible party would be unallowable, and the awarding agency could potentially recover them. We subsequently verified the contractors were not suspended or debarred. Therefore, we are not questioning costs. Recommendation We recommend the District strengthen its internal controls to verify all contractors it pays $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs and maintain documentation demonstrating compliance with this requirement. District’s Response The cooperative provides all bid documents for the district representatives to review, this included suspension and debarment documentation. After review at a meeting of the cooperative membership, the members vote on accepting the bid. The cooperative keeps all documentation on file for review of the auditors. Documentation of this was provided to the auditor. Auditor’s Remarks We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District’s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 180, OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement), establishes nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689.
Finding ref number: 2025-001 Finding caption: The District did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Name, address, and telephone of District contact person: Jaime Matisons, Food Service Manager, 900 Cleveland, Aberdeen, WA. 98520 (360) 538-2256 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for non-concurrence). The cooperative provides all bid documents for the district representatives to review, this included suspension and debarment documentation. After review at a meeting of the cooperative membership, the members vote on accepting the bid. The cooperative keeps all documentation on file for review of the auditors. Documentation of this was provided to the auditor. Anticipated date to complete the corrective action: April 2026
2025-002 The District did not have adequate internal controls and did not comply with time-and-effort requirements. Assistance Listing Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: S010A230047 S367A230045 Known Questioned Cost Amount: $0 Prior Year Audit Finding: N/A Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. During the 2024-25 school year, the District spent $1,907,696 in Title I program funds. Federal regulations require recipients to establish, document and maintain effective internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs it charges to the program with adequate time-and-effort documentation, as required by federal regulations and the awarding agency. Depending on the number and types of activities employees perform, time-and-effort documentation can be a semiannual certification or a monthly personnel activity report (PAR), such as a detailed timesheet. Time-and-effort documentation must also be signed and dated after employees complete the work. Description of Condition The District’s internal controls were ineffective for ensuring it supported all salaries and benefits it charged to the program with appropriate time and effort documentation, as federal regulations and OSPI require. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. Cause of Condition District staff were aware of the federal time-and-effort certification requirements, but overlooked the requirements in some cases and did not ensure that the time-and-effort documentation was dated. Effect of Condition The District did not obtain adequate time-and-effort documentation for two out of 14 employees tested whose payroll costs totaling $212,505 it charged to the program. Specifically, the two employees completed annual time-and-effort certifications for time worked in the program but did not complete either a semiannual certification or monthly PAR as OSPI requires. The employees also did not date the annual certifications to demonstrate they were signed after the work was completed. Additionally, using a nonstatistical sample, we found one out of nine employees tested (11%) whose salaries and benefits totaling $5,966 were not supported by adequate time-and-effort documentation. Specifically, the employee had one monthly PAR out of 10 months tested that they did not date to demonstrate it was signed after they completed the work. Without adequate time-and-effort documentation, the District cannot demonstrate compliance with the awarding agency’s documentation requirements to support costs charged to federal programs. During the audit, the District provided alternative documentation to support the payroll costs it charged to the program; therefore, we are not questioning these costs. Recommendation We recommend the District implement and follow internal controls to ensure it complies with federal and OSPI requirements for obtaining signed and dated time-and-effort documentation timely. District’s Response The district will make sure all staff are listed on the Semi-Annual Certifications. Staff with braided funding will have a PAR with monthly verifications. Auditor’s Remarks We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District’s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction Bulletin 039-24, Financial Resources establishes requirements for documenting time-and-effort.
Show full finding ▾Hide full finding ▴2025-002 The District did not have adequate internal controls and did not comply with time-and-effort requirements. Assistance Listing Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: S010A230047 S367A230045 Known Questioned Cost Amount: $0 Prior Year Audit Finding: N/A Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. During the 2024-25 school year, the District spent $1,907,696 in Title I program funds. Federal regulations require recipients to establish, document and maintain effective internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs it charges to the program with adequate time-and-effort documentation, as required by federal regulations and the awarding agency. Depending on the number and types of activities employees perform, time-and-effort documentation can be a semiannual certification or a monthly personnel activity report (PAR), such as a detailed timesheet. Time-and-effort documentation must also be signed and dated after employees complete the work. Description of Condition The District’s internal controls were ineffective for ensuring it supported all salaries and benefits it charged to the program with appropriate time and effort documentation, as federal regulations and OSPI require. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. Cause of Condition District staff were aware of the federal time-and-effort certification requirements, but overlooked the requirements in some cases and did not ensure that the time-and-effort documentation was dated. Effect of Condition The District did not obtain adequate time-and-effort documentation for two out of 14 employees tested whose payroll costs totaling $212,505 it charged to the program. Specifically, the two employees completed annual time-and-effort certifications for time worked in the program but did not complete either a semiannual certification or monthly PAR as OSPI requires. The employees also did not date the annual certifications to demonstrate they were signed after the work was completed. Additionally, using a nonstatistical sample, we found one out of nine employees tested (11%) whose salaries and benefits totaling $5,966 were not supported by adequate time-and-effort documentation. Specifically, the employee had one monthly PAR out of 10 months tested that they did not date to demonstrate it was signed after they completed the work. Without adequate time-and-effort documentation, the District cannot demonstrate compliance with the awarding agency’s documentation requirements to support costs charged to federal programs. During the audit, the District provided alternative documentation to support the payroll costs it charged to the program; therefore, we are not questioning these costs. Recommendation We recommend the District implement and follow internal controls to ensure it complies with federal and OSPI requirements for obtaining signed and dated time-and-effort documentation timely. District’s Response The district will make sure all staff are listed on the Semi-Annual Certifications. Staff with braided funding will have a PAR with monthly verifications. Auditor’s Remarks We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District’s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction Bulletin 039-24, Financial Resources establishes requirements for documenting time-and-effort.
Finding ref number: 2025-002 Finding caption: The District did not have adequate internal controls and did not comply with time-and-effort requirements. Name, address, and telephone of District contact person: Elyssa Louderback, Executive Director of Business & Operations, 216 North G Street, Aberdeen, WA. 98520. (360) 538-2007 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for non-concurrence). The district will make sure all staff are listed on the Semi-Annual Certifications. Staff with braided funding will have a PAR with monthly verifications. Anticipated date to complete the corrective action: February 1, 2026
FAC accepted this audit on May 14, 2025 — management decision was due November 14, 2025.
FAC accepted this audit on May 10, 2024 — management decision was due November 10, 2024.
2023-001 The District’s internal controls were inadequate for ensuring compliance with time and effort requirements. Assistance Listing Number and Title: 84.027, Special Education Grants to States 84.173, Special Education Preschool Grants Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: 307823/367215 Known Questioned Cost Amount: N/A Prior Year Audit Finding: N/A Background During fiscal year 2023, the District spent $865,457 of its Special Education Program funds. This program ensures students with disabilities receive free and appropriate public education with specially designed instruction that addresses their unique needs. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. Those controls include understanding program requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs it charges to the program with adequate time and effort documentation, as required by federal regulations and the awarding agency. Depending on the number and type of activities employees perform, time and effort documentation can be a semiannual certification or a monthly personnel activity report, such as a detailed timesheet. Time and effort documentation must also be signed and dated after the work is completed. Description of Condition The District’s internal controls were ineffective for ensuring it supported all salaries and benefits it charged to the program with appropriate time and effort documentation, as federal regulations and OSPI require. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. Cause of Condition Turnover in the District’s key positions responsible for managing the program resulted in an oversight in ensuring compliance with time and effort requirements. Effect of Condition The District did not obtain time and effort documentation for all employees whose payroll and benefits costs it charged to the program, totaling $696,887. Without adequate time and effort documentation, the District cannot demonstrate compliance with the awarding agency’s documentation requirements that support costs charged to federal programs. Further, the District cannot assure federal grantors that payroll costs it charged to the program were accurate and valid. During the audit, the District obtained and provided the signed time and effort records to support the payroll costs it charged to the program; therefore, we are not questioning these costs. Recommendation We recommend the District establish and follow internal controls to ensure it complies with federal and OSPI requirements for obtaining signed time and effort documentation timely. District’s Response The district was in transition with staff overseeing time and effort for the year inquestion. Staff salaries were reviewed at the end of the year by the Business Office with communication from the buildings to verify staff were paid from the appropriate programs. The building staff that were requested to sign the Semi Annual certification forms for time and effort documentation after the close of the fiscal year and date them for the time period that they were specific to. In the future, the district will request staff sign the Semi Annual certification forms and date them for the day they are being signed. Auditor’s Remarks We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District’s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction Addendum to Bulletin 048-17, establishes requirements for documenting time and effort.
Show full finding ▾Hide full finding ▴2023-001 The District’s internal controls were inadequate for ensuring compliance with time and effort requirements. Assistance Listing Number and Title: 84.027, Special Education Grants to States 84.173, Special Education Preschool Grants Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: 307823/367215 Known Questioned Cost Amount: N/A Prior Year Audit Finding: N/A Background During fiscal year 2023, the District spent $865,457 of its Special Education Program funds. This program ensures students with disabilities receive free and appropriate public education with specially designed instruction that addresses their unique needs. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. Those controls include understanding program requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs it charges to the program with adequate time and effort documentation, as required by federal regulations and the awarding agency. Depending on the number and type of activities employees perform, time and effort documentation can be a semiannual certification or a monthly personnel activity report, such as a detailed timesheet. Time and effort documentation must also be signed and dated after the work is completed. Description of Condition The District’s internal controls were ineffective for ensuring it supported all salaries and benefits it charged to the program with appropriate time and effort documentation, as federal regulations and OSPI require. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. Cause of Condition Turnover in the District’s key positions responsible for managing the program resulted in an oversight in ensuring compliance with time and effort requirements. Effect of Condition The District did not obtain time and effort documentation for all employees whose payroll and benefits costs it charged to the program, totaling $696,887. Without adequate time and effort documentation, the District cannot demonstrate compliance with the awarding agency’s documentation requirements that support costs charged to federal programs. Further, the District cannot assure federal grantors that payroll costs it charged to the program were accurate and valid. During the audit, the District obtained and provided the signed time and effort records to support the payroll costs it charged to the program; therefore, we are not questioning these costs. Recommendation We recommend the District establish and follow internal controls to ensure it complies with federal and OSPI requirements for obtaining signed time and effort documentation timely. District’s Response The district was in transition with staff overseeing time and effort for the year inquestion. Staff salaries were reviewed at the end of the year by the Business Office with communication from the buildings to verify staff were paid from the appropriate programs. The building staff that were requested to sign the Semi Annual certification forms for time and effort documentation after the close of the fiscal year and date them for the time period that they were specific to. In the future, the district will request staff sign the Semi Annual certification forms and date them for the day they are being signed. Auditor’s Remarks We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District’s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction Addendum to Bulletin 048-17, establishes requirements for documenting time and effort.
Finding ref number: 2023-001 Finding caption: The District’s internal controls were inadequate for ensuring compliance with time and effort requirements. Name, address, and telephone of District contact person: Elyssa Louderback, Executive Director of Business & Operations 216 N. G Street, Aberdeen, WA 98520 (360) 538-2007 Corrective action the auditee plans to take in response to the finding: The district was in transition with staff overseeing time and effort for the year in question. Staff salaries were reviewed at the end of the year by the Business Office with communication from the buildings to verify staff were paid from the appropriate programs. The building staff that were requested to sign the Semi Annual certification forms for time and effort documentation after the close of the fiscal year and date them for the time period that they were specific to. In the future, the district will request staff sign the Semi Annual certification forms and date them for the day they are being signed. Anticipated date to complete the corrective action: March 1, 2024
FAC accepted this audit on May 21, 2023 — management decision was due November 21, 2023.
Aberdeen School District No. 5 September 1, 2021 through August 31, 2022 2022-001 The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Assistance Listing Number and Title: 84.027 ? Special Education Grants to States 84.027 ? COVID-19 ? Special Education Grants to States 84.173 ? Special Education ? Preschool Grants 84.173 ? COVID-19 ? Special Education Preschool Grants Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: N/A Known Questioned Cost Amount: $0 Description of Condition During the 2021-2022 school year, the District spent $1,029,182 in Special Education program funds. The objective of the Special Education program is to help education agencies provide special education and related services to all children with disabilities. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established program controls. Federal regulations also require grant recipients to follow their own written procurement procedures, which must reflect the most restrictive of applicable federal, state or local laws. Federal regulations and District policy require the District to obtain price or rate quotes from an adequate number of sources for any services more than $10,000 but less than $250,000. For personal service contracts more than $250,000, the District must solicit sealed bids or competitive proposals. The District must also keep records to demonstrate compliance with these requirements. The District paid $345,952 and $65,860 for two personal service contracts using federal funds. Our audit found the District did not follow federal requirements and its own policy to procure personal services. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. The issue was not reported as a finding in the prior. Cause of Condition The District cannot demonstrate it received the best price for the services purchased and is not in compliance with federal requirements. Effect of Condition The District cannot demonstrate it received the best price for the services purchased and is not in compliance with federal requirements. Recommendation We recommend the District establish internal controls to ensure it follows the most restrictive procurement procedures when using federal funds to procure goods or services. Further, we recommend the District ensure it maintains documentation necessary to demonstrate compliance with these procurement requirements. District?s Response The district made best effort attempts to comply with the procurement guidance and has made changes in the process to fully comply in the future. Auditor?s Remarks We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Section 319 ? Competition, establishes all procurement transactions are to be conducted in a manner providing full and open competition, and requires non-federal entities to have written procedures for procurement transactions. Title 2 CFR Part 200, Section 320 ? Methods of procurement to be followed, describes each allowable procurement method.
Show full finding ▾Hide full finding ▴Aberdeen School District No. 5 September 1, 2021 through August 31, 2022 2022-001 The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Assistance Listing Number and Title: 84.027 ? Special Education Grants to States 84.027 ? COVID-19 ? Special Education Grants to States 84.173 ? Special Education ? Preschool Grants 84.173 ? COVID-19 ? Special Education Preschool Grants Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: N/A Known Questioned Cost Amount: $0 Description of Condition During the 2021-2022 school year, the District spent $1,029,182 in Special Education program funds. The objective of the Special Education program is to help education agencies provide special education and related services to all children with disabilities. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established program controls. Federal regulations also require grant recipients to follow their own written procurement procedures, which must reflect the most restrictive of applicable federal, state or local laws. Federal regulations and District policy require the District to obtain price or rate quotes from an adequate number of sources for any services more than $10,000 but less than $250,000. For personal service contracts more than $250,000, the District must solicit sealed bids or competitive proposals. The District must also keep records to demonstrate compliance with these requirements. The District paid $345,952 and $65,860 for two personal service contracts using federal funds. Our audit found the District did not follow federal requirements and its own policy to procure personal services. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. The issue was not reported as a finding in the prior. Cause of Condition The District cannot demonstrate it received the best price for the services purchased and is not in compliance with federal requirements. Effect of Condition The District cannot demonstrate it received the best price for the services purchased and is not in compliance with federal requirements. Recommendation We recommend the District establish internal controls to ensure it follows the most restrictive procurement procedures when using federal funds to procure goods or services. Further, we recommend the District ensure it maintains documentation necessary to demonstrate compliance with these procurement requirements. District?s Response The district made best effort attempts to comply with the procurement guidance and has made changes in the process to fully comply in the future. Auditor?s Remarks We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Section 319 ? Competition, establishes all procurement transactions are to be conducted in a manner providing full and open competition, and requires non-federal entities to have written procedures for procurement transactions. Title 2 CFR Part 200, Section 320 ? Methods of procurement to be followed, describes each allowable procurement method.
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Aberdeen School District No. 5 September 1, 2021 through August 31, 2022 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of District contact person: Elyssa Louderback, Fiscal Consultant 216 N. G Street, Aberdeen, WA 98520, (360)538-2007 Corrective action the auditee plans to take in response to the finding: The district will issue an RFP annually, with an option to extend the contract. The district will keep records of the cost analysis each time a need is identified and a provider is hired to fill that need. Additionally at the beginning of the year, the district will do a cost analysis based on the responses of the RFP per vendor with the services they are to be contracted. A staff member will also attend Procurement Boot camp training in compliance with OMB Uniform Grant Guidance. Anticipated date to complete the corrective action: July 2023
The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Assistance Listing Number and Title: 84.027 – Special Education Grants to States 84.027 – COVID-19 – Special Education Grants to States 84.173 – Special Education – Preschool Grants 84.173 – COVID-19 – Special Education Preschool Grants Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: N/A Known Questioned Cost Amount: $0 Description of Condition During the 2021-2022 school year, the District spent $1,029,182 in Special Education program funds. The objective of the Special Education program is to help education agencies provide special education and related services to all children with disabilities. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established program controls. Federal regulations also require grant recipients to follow their own written procurement procedures, which must reflect the most restrictive of applicable federal, state or local laws. Federal regulations and District policy require the District to obtain price or rate quotes from an adequate number of sources for any services more than $10,000 but less than $250,000. For personal service contracts more than $250,000, the District must solicit sealed bids or competitive proposals. The District must also keep records to demonstrate compliance with these requirements. The District paid $345,952 and $65,860 for two personal service contracts using federal funds. Our audit found the District did not follow federal requirements and its own policy to procure personal services. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. The issue was not reported as a finding in the prior. Cause of Condition Management said they thought the District could rely on a request for proposal process and quotes it had received in a prior period for the contracts. Effect of Condition The District cannot demonstrate it received the best price for the services purchased and is not in compliance with federal requirements. Recommendation We recommend the District establish internal controls to ensure it follows the most restrictive procurement procedures when using federal funds to procure goods or services. Further, we recommend the District ensure it maintains documentation necessary to demonstrate compliance with these procurement requirements. District’s Response The district made best effort attempts to comply with the procurement guidance and has made changes in the process to fully comply in the future. Auditor’s Remarks We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District’s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Section 319 – Competition, establishes all procurement transactions are to be conducted in a manner providing full and open competition, and requires non-federal entities to have written procedures for procurement transactions. Title 2 CFR Part 200, Section 320 – Methods of procurement to be followed, describes each allowable procurement method.
Show full finding ▾Hide full finding ▴The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Assistance Listing Number and Title: 84.027 – Special Education Grants to States 84.027 – COVID-19 – Special Education Grants to States 84.173 – Special Education – Preschool Grants 84.173 – COVID-19 – Special Education Preschool Grants Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: N/A Known Questioned Cost Amount: $0 Description of Condition During the 2021-2022 school year, the District spent $1,029,182 in Special Education program funds. The objective of the Special Education program is to help education agencies provide special education and related services to all children with disabilities. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established program controls. Federal regulations also require grant recipients to follow their own written procurement procedures, which must reflect the most restrictive of applicable federal, state or local laws. Federal regulations and District policy require the District to obtain price or rate quotes from an adequate number of sources for any services more than $10,000 but less than $250,000. For personal service contracts more than $250,000, the District must solicit sealed bids or competitive proposals. The District must also keep records to demonstrate compliance with these requirements. The District paid $345,952 and $65,860 for two personal service contracts using federal funds. Our audit found the District did not follow federal requirements and its own policy to procure personal services. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. The issue was not reported as a finding in the prior. Cause of Condition Management said they thought the District could rely on a request for proposal process and quotes it had received in a prior period for the contracts. Effect of Condition The District cannot demonstrate it received the best price for the services purchased and is not in compliance with federal requirements. Recommendation We recommend the District establish internal controls to ensure it follows the most restrictive procurement procedures when using federal funds to procure goods or services. Further, we recommend the District ensure it maintains documentation necessary to demonstrate compliance with these procurement requirements. District’s Response The district made best effort attempts to comply with the procurement guidance and has made changes in the process to fully comply in the future. Auditor’s Remarks We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District’s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Section 319 – Competition, establishes all procurement transactions are to be conducted in a manner providing full and open competition, and requires non-federal entities to have written procedures for procurement transactions. Title 2 CFR Part 200, Section 320 – Methods of procurement to be followed, describes each allowable procurement method.
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Aberdeen School District No. 5 September 1, 2021 through August 31, 2022 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of District contact person: Elyssa Louderback, Fiscal Consultant 216 N. G Street, Aberdeen, WA 98520, (360)538-2007 Corrective action the auditee plans to take in response to the finding: The district will issue an RFP annually, with an option to extend the contract. The district will keep records of the cost analysis each time a need is identified and a provider is hired to fill that need. Additionally at the beginning of the year, the district will do a cost analysis based on the responses of the RFP per vendor with the services they are to be contracted. A staff member will also attend Procurement Boot camp training in compliance with OMB Uniform Grant Guidance. Anticipated date to complete the corrective action: July 2023
FAC accepted this audit on April 2, 2024 — management decision was due October 2, 2024.
Aberdeen School District No. 5 September 1, 2021 through August 31, 2022 2022-001 The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Assistance Listing Number and Title: 84.027 ? Special Education Grants to States 84.027 ? COVID-19 ? Special Education Grants to States 84.173 ? Special Education ? Preschool Grants 84.173 ? COVID-19 ? Special Education Preschool Grants Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: N/A Known Questioned Cost Amount: $0 Description of Condition During the 2021-2022 school year, the District spent $1,029,182 in Special Education program funds. The objective of the Special Education program is to help education agencies provide special education and related services to all children with disabilities. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established program controls. Federal regulations also require grant recipients to follow their own written procurement procedures, which must reflect the most restrictive of applicable federal, state or local laws. Federal regulations and District policy require the District to obtain price or rate quotes from an adequate number of sources for any services more than $10,000 but less than $250,000. For personal service contracts more than $250,000, the District must solicit sealed bids or competitive proposals. The District must also keep records to demonstrate compliance with these requirements. The District paid $345,952 and $65,860 for two personal service contracts using federal funds. Our audit found the District did not follow federal requirements and its own policy to procure personal services. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. The issue was not reported as a finding in the prior. Cause of Condition The District cannot demonstrate it received the best price for the services purchased and is not in compliance with federal requirements. Effect of Condition The District cannot demonstrate it received the best price for the services purchased and is not in compliance with federal requirements. Recommendation We recommend the District establish internal controls to ensure it follows the most restrictive procurement procedures when using federal funds to procure goods or services. Further, we recommend the District ensure it maintains documentation necessary to demonstrate compliance with these procurement requirements. District?s Response The district made best effort attempts to comply with the procurement guidance and has made changes in the process to fully comply in the future. Auditor?s Remarks We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Section 319 ? Competition, establishes all procurement transactions are to be conducted in a manner providing full and open competition, and requires non-federal entities to have written procedures for procurement transactions. Title 2 CFR Part 200, Section 320 ? Methods of procurement to be followed, describes each allowable procurement method.
Show full finding ▾Hide full finding ▴Aberdeen School District No. 5 September 1, 2021 through August 31, 2022 2022-001 The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Assistance Listing Number and Title: 84.027 ? Special Education Grants to States 84.027 ? COVID-19 ? Special Education Grants to States 84.173 ? Special Education ? Preschool Grants 84.173 ? COVID-19 ? Special Education Preschool Grants Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: N/A Known Questioned Cost Amount: $0 Description of Condition During the 2021-2022 school year, the District spent $1,029,182 in Special Education program funds. The objective of the Special Education program is to help education agencies provide special education and related services to all children with disabilities. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established program controls. Federal regulations also require grant recipients to follow their own written procurement procedures, which must reflect the most restrictive of applicable federal, state or local laws. Federal regulations and District policy require the District to obtain price or rate quotes from an adequate number of sources for any services more than $10,000 but less than $250,000. For personal service contracts more than $250,000, the District must solicit sealed bids or competitive proposals. The District must also keep records to demonstrate compliance with these requirements. The District paid $345,952 and $65,860 for two personal service contracts using federal funds. Our audit found the District did not follow federal requirements and its own policy to procure personal services. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. The issue was not reported as a finding in the prior. Cause of Condition The District cannot demonstrate it received the best price for the services purchased and is not in compliance with federal requirements. Effect of Condition The District cannot demonstrate it received the best price for the services purchased and is not in compliance with federal requirements. Recommendation We recommend the District establish internal controls to ensure it follows the most restrictive procurement procedures when using federal funds to procure goods or services. Further, we recommend the District ensure it maintains documentation necessary to demonstrate compliance with these procurement requirements. District?s Response The district made best effort attempts to comply with the procurement guidance and has made changes in the process to fully comply in the future. Auditor?s Remarks We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Section 319 ? Competition, establishes all procurement transactions are to be conducted in a manner providing full and open competition, and requires non-federal entities to have written procedures for procurement transactions. Title 2 CFR Part 200, Section 320 ? Methods of procurement to be followed, describes each allowable procurement method.
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Aberdeen School District No. 5 September 1, 2021 through August 31, 2022 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of District contact person: Elyssa Louderback, Fiscal Consultant 216 N. G Street, Aberdeen, WA 98520, (360)538-2007 Corrective action the auditee plans to take in response to the finding: The district will issue an RFP annually, with an option to extend the contract. The district will keep records of the cost analysis each time a need is identified and a provider is hired to fill that need. Additionally at the beginning of the year, the district will do a cost analysis based on the responses of the RFP per vendor with the services they are to be contracted. A staff member will also attend Procurement Boot camp training in compliance with OMB Uniform Grant Guidance. Anticipated date to complete the corrective action: July 2023
The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Assistance Listing Number and Title: 84.027 – Special Education Grants to States 84.027 – COVID-19 – Special Education Grants to States 84.173 – Special Education – Preschool Grants 84.173 – COVID-19 – Special Education Preschool Grants Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: N/A Known Questioned Cost Amount: $0 Description of Condition During the 2021-2022 school year, the District spent $1,029,182 in Special Education program funds. The objective of the Special Education program is to help education agencies provide special education and related services to all children with disabilities. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established program controls. Federal regulations also require grant recipients to follow their own written procurement procedures, which must reflect the most restrictive of applicable federal, state or local laws. Federal regulations and District policy require the District to obtain price or rate quotes from an adequate number of sources for any services more than $10,000 but less than $250,000. For personal service contracts more than $250,000, the District must solicit sealed bids or competitive proposals. The District must also keep records to demonstrate compliance with these requirements. The District paid $345,952 and $65,860 for two personal service contracts using federal funds. Our audit found the District did not follow federal requirements and its own policy to procure personal services. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. The issue was not reported as a finding in the prior. Cause of Condition Management said they thought the District could rely on a request for proposal process and quotes it had received in a prior period for the contracts. Effect of Condition The District cannot demonstrate it received the best price for the services purchased and is not in compliance with federal requirements. Recommendation We recommend the District establish internal controls to ensure it follows the most restrictive procurement procedures when using federal funds to procure goods or services. Further, we recommend the District ensure it maintains documentation necessary to demonstrate compliance with these procurement requirements. District’s Response The district made best effort attempts to comply with the procurement guidance and has made changes in the process to fully comply in the future. Auditor’s Remarks We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District’s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Section 319 – Competition, establishes all procurement transactions are to be conducted in a manner providing full and open competition, and requires non-federal entities to have written procedures for procurement transactions. Title 2 CFR Part 200, Section 320 – Methods of procurement to be followed, describes each allowable procurement method.
Show full finding ▾Hide full finding ▴The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Assistance Listing Number and Title: 84.027 – Special Education Grants to States 84.027 – COVID-19 – Special Education Grants to States 84.173 – Special Education – Preschool Grants 84.173 – COVID-19 – Special Education Preschool Grants Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: N/A Known Questioned Cost Amount: $0 Description of Condition During the 2021-2022 school year, the District spent $1,029,182 in Special Education program funds. The objective of the Special Education program is to help education agencies provide special education and related services to all children with disabilities. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established program controls. Federal regulations also require grant recipients to follow their own written procurement procedures, which must reflect the most restrictive of applicable federal, state or local laws. Federal regulations and District policy require the District to obtain price or rate quotes from an adequate number of sources for any services more than $10,000 but less than $250,000. For personal service contracts more than $250,000, the District must solicit sealed bids or competitive proposals. The District must also keep records to demonstrate compliance with these requirements. The District paid $345,952 and $65,860 for two personal service contracts using federal funds. Our audit found the District did not follow federal requirements and its own policy to procure personal services. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. The issue was not reported as a finding in the prior. Cause of Condition Management said they thought the District could rely on a request for proposal process and quotes it had received in a prior period for the contracts. Effect of Condition The District cannot demonstrate it received the best price for the services purchased and is not in compliance with federal requirements. Recommendation We recommend the District establish internal controls to ensure it follows the most restrictive procurement procedures when using federal funds to procure goods or services. Further, we recommend the District ensure it maintains documentation necessary to demonstrate compliance with these procurement requirements. District’s Response The district made best effort attempts to comply with the procurement guidance and has made changes in the process to fully comply in the future. Auditor’s Remarks We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District’s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Section 319 – Competition, establishes all procurement transactions are to be conducted in a manner providing full and open competition, and requires non-federal entities to have written procedures for procurement transactions. Title 2 CFR Part 200, Section 320 – Methods of procurement to be followed, describes each allowable procurement method.
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Aberdeen School District No. 5 September 1, 2021 through August 31, 2022 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of District contact person: Elyssa Louderback, Fiscal Consultant 216 N. G Street, Aberdeen, WA 98520, (360)538-2007 Corrective action the auditee plans to take in response to the finding: The district will issue an RFP annually, with an option to extend the contract. The district will keep records of the cost analysis each time a need is identified and a provider is hired to fill that need. Additionally at the beginning of the year, the district will do a cost analysis based on the responses of the RFP per vendor with the services they are to be contracted. A staff member will also attend Procurement Boot camp training in compliance with OMB Uniform Grant Guidance. Anticipated date to complete the corrective action: July 2023
FAC accepted this audit on May 24, 2022 — management decision was due November 24, 2022.
2021-001 The District?s internal controls were inadequate for ensuring compliance with federal requirements for Title I eligibility. CFDA Number and Title: 84.010 ? Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: 203818, 224750, 270554 Questioned Cost Amount: $0 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. During the 2020-2021 school year, the District spent $1,590,048 in Title I program funds. Federal regulations require recipients establish and follow internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. Title I requires participating districts to allocate more funds to schools with higher poverty percentages. Districts must rank schools from highest to lowest poverty concentrations based on the total number of students from low-income families attending the school or residing in the area. For districts with 1,000 or more students enrolled, any buildings with a poverty rate higher than 75 percent must be included. The rankings are included in the Title I application, and districts must maintain documentation supporting their rankings. Description of Condition Our audit found the District?s internal controls were inadequate for ensuring compliance with Title I eligibility requirements. Specifically, the District incorrectly included preschool student family income data as part of the income data it used for ranking and allocating funding to Title I school buildings. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. The issue was reported as a finding in the prior audit as finding 2020-002. Cause of Condition District officials were aware that preschool student income data should be excluded when determining Title I building rankings and funding allocations. However, District staff responsible for preparing the Title I application forgot to remove the preschool student income data. Further, the District did not have a secondary review in place to ensure the accuracy of the income data included in the application. Effect of Condition The District cannot demonstrate compliance with federal requirements for allocating Title I funds to eligible schools. Based on corrected income data, Stevens Elementary incorrectly received $101 per pupil more in Title I funding than five other schools with higher poverty percentages. Recommendation We recommend the District establish and follow internal controls to ensure it uses correct income data for determining Title I building rankings and funding allocations. District?s Response The district included preschool students in the count of eligible students at the elementary school site that hosts that program. This impacted the rank and allocation process. The district has new administrators responsible for this program that continue to learn the intricacies. The district attends quarterly meetings with ESD and OSPI for program updates and ask questions. Additionally they reach out to OSPI on other occasions as needed. The district appreciates the SAO review and input. Auditor?s Remarks We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 34 CFR, Part 200, Title I ? Improving the Academic Achievement of the Disadvantaged, Subpart A ? Improving Basic Programs Operated by Local Education Agencies, Section 78 ? Allocation of funds to school attendance areas and schools.
Show full finding ▾Hide full finding ▴2021-001 The District?s internal controls were inadequate for ensuring compliance with federal requirements for Title I eligibility. CFDA Number and Title: 84.010 ? Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: 203818, 224750, 270554 Questioned Cost Amount: $0 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. During the 2020-2021 school year, the District spent $1,590,048 in Title I program funds. Federal regulations require recipients establish and follow internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. Title I requires participating districts to allocate more funds to schools with higher poverty percentages. Districts must rank schools from highest to lowest poverty concentrations based on the total number of students from low-income families attending the school or residing in the area. For districts with 1,000 or more students enrolled, any buildings with a poverty rate higher than 75 percent must be included. The rankings are included in the Title I application, and districts must maintain documentation supporting their rankings. Description of Condition Our audit found the District?s internal controls were inadequate for ensuring compliance with Title I eligibility requirements. Specifically, the District incorrectly included preschool student family income data as part of the income data it used for ranking and allocating funding to Title I school buildings. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. The issue was reported as a finding in the prior audit as finding 2020-002. Cause of Condition District officials were aware that preschool student income data should be excluded when determining Title I building rankings and funding allocations. However, District staff responsible for preparing the Title I application forgot to remove the preschool student income data. Further, the District did not have a secondary review in place to ensure the accuracy of the income data included in the application. Effect of Condition The District cannot demonstrate compliance with federal requirements for allocating Title I funds to eligible schools. Based on corrected income data, Stevens Elementary incorrectly received $101 per pupil more in Title I funding than five other schools with higher poverty percentages. Recommendation We recommend the District establish and follow internal controls to ensure it uses correct income data for determining Title I building rankings and funding allocations. District?s Response The district included preschool students in the count of eligible students at the elementary school site that hosts that program. This impacted the rank and allocation process. The district has new administrators responsible for this program that continue to learn the intricacies. The district attends quarterly meetings with ESD and OSPI for program updates and ask questions. Additionally they reach out to OSPI on other occasions as needed. The district appreciates the SAO review and input. Auditor?s Remarks We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 34 CFR, Part 200, Title I ? Improving the Academic Achievement of the Disadvantaged, Subpart A ? Improving Basic Programs Operated by Local Education Agencies, Section 78 ? Allocation of funds to school attendance areas and schools.
Finding ref number: 2021-001 Finding caption: The District?s internal controls were inadequate for ensuring compliance with federal requirements for Title I eligibility. Name, address, and telephone of District contact person: Elyssa Louderback, Executive Director of Business & Operations 2 16 N. G Street Aberdeen, WA 98520 (360) 538-2007 Corrective action the auditee plans to take in response to the finding: The district included preschool students in the count of eligible students at the elementary school site that hosts that program. This impacted the rank and allocation process. The district has new administrators responsible for this program that continue to learn the intricacies. The district attends quarterly meetings with ESD and OSPI for program updates and ask questions. Additionally they reach out to OSPI on other occasions as needed. The district appreciates the SAO review and input. Anticipated date to complete the corrective action: April, 2022
2020-002
2021-002 The District had inadequate internal controls for ensuring compliance with suspension and debarment requirements. CFDA Number and Title: 10.555 ? National School Lunch Program 10.555 ? COVID-19 ? National School Lunch Program 10.559 ? Summer Food Service Program for Children Federal Grantor Name: U.S. Department of Agriculture (USDA) Federal Award/Contract Number: N/A Pass-through Entity Name: Office of the Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: 14-005 Questioned Cost Amount: $0 Description of Condition The District participates in the National School Lunch Program and the Summer Food Service Program for Children. During the 2020-2021 school year, the District spent $1,845,315 in federal funding to administer these programs. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. Federal requirements prohibit grant recipients from contracting with or purchasing from parties suspended or debarred from doing business with the federalvgovernment. Whenever the District contracts for goods and services that it expects to equal or exceed $25,000, paid all or in part with federal funds, it must verify the contractor is not suspended, debarred or otherwise excluded. The District may verify a contractor?s status by obtaining written certification from the contractor, or it can insert a clause into the contract stating the contractor is not suspended or debarred. Alternatively, the District may check the U.S. General Services Administration?s Excluded Parties List System (EPLS). The District must meet one of these verification requirements and retain supporting documentation demonstrating compliance with this federal requirement before contracting or purchasing. The District lacked adequate internal controls for verifying the eligibility of two contractors that were paid $52,343 and $33,305 in 2021. We consider this deficiency to be a material weakness that led to material noncompliance with federal requirements. The issue was reported as a finding in the prior audit as finding 2020-001. Cause of Condition The District?s normal process is to include suspension and debarment language in contracts. However, the employee responsible for the process did not know a contract was required for these purchases, and as such, did not establish one. As a result, the District did not verify the contractors? status before making the purchases. Effect of Condition Without adequate internal controls, the District cannot ensure the contractors it paid with federal funds are eligible to participate in federal programs. Any program funds the District used to pay contractors that have been suspended or debarred would be unallowable and the grantor could potentially recover them. We verified the contractors were not suspended or debarred. Therefore, we are not questioning the related costs. Recommendation We recommend the District follow its established internal controls for verifying the suspension and debarment status of contractors paid $25,000 or more, all or in part with federal funds, before contracting or purchasing. District?s Response The district has been working through a challenging supply chain climate. If we know that we are going to spend over $10,000 in federal funds, we will now look the vendor up in the SAM data base. One of the vendors in question changed ownership and the district did not combine the totals for both vendors to review amounts for suspension and debarment. Auditor?s Remarks We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 180, OMB, Guidelines to Agencies on Government wide Debarment and Suspension (Nonprocurement) establishes non-procurement debarment and suspension regulations, implementing Executive Orders 12549 and 12689.
Show full finding ▾Hide full finding ▴2021-002 The District had inadequate internal controls for ensuring compliance with suspension and debarment requirements. CFDA Number and Title: 10.555 ? National School Lunch Program 10.555 ? COVID-19 ? National School Lunch Program 10.559 ? Summer Food Service Program for Children Federal Grantor Name: U.S. Department of Agriculture (USDA) Federal Award/Contract Number: N/A Pass-through Entity Name: Office of the Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: 14-005 Questioned Cost Amount: $0 Description of Condition The District participates in the National School Lunch Program and the Summer Food Service Program for Children. During the 2020-2021 school year, the District spent $1,845,315 in federal funding to administer these programs. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. Federal requirements prohibit grant recipients from contracting with or purchasing from parties suspended or debarred from doing business with the federalvgovernment. Whenever the District contracts for goods and services that it expects to equal or exceed $25,000, paid all or in part with federal funds, it must verify the contractor is not suspended, debarred or otherwise excluded. The District may verify a contractor?s status by obtaining written certification from the contractor, or it can insert a clause into the contract stating the contractor is not suspended or debarred. Alternatively, the District may check the U.S. General Services Administration?s Excluded Parties List System (EPLS). The District must meet one of these verification requirements and retain supporting documentation demonstrating compliance with this federal requirement before contracting or purchasing. The District lacked adequate internal controls for verifying the eligibility of two contractors that were paid $52,343 and $33,305 in 2021. We consider this deficiency to be a material weakness that led to material noncompliance with federal requirements. The issue was reported as a finding in the prior audit as finding 2020-001. Cause of Condition The District?s normal process is to include suspension and debarment language in contracts. However, the employee responsible for the process did not know a contract was required for these purchases, and as such, did not establish one. As a result, the District did not verify the contractors? status before making the purchases. Effect of Condition Without adequate internal controls, the District cannot ensure the contractors it paid with federal funds are eligible to participate in federal programs. Any program funds the District used to pay contractors that have been suspended or debarred would be unallowable and the grantor could potentially recover them. We verified the contractors were not suspended or debarred. Therefore, we are not questioning the related costs. Recommendation We recommend the District follow its established internal controls for verifying the suspension and debarment status of contractors paid $25,000 or more, all or in part with federal funds, before contracting or purchasing. District?s Response The district has been working through a challenging supply chain climate. If we know that we are going to spend over $10,000 in federal funds, we will now look the vendor up in the SAM data base. One of the vendors in question changed ownership and the district did not combine the totals for both vendors to review amounts for suspension and debarment. Auditor?s Remarks We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 180, OMB, Guidelines to Agencies on Government wide Debarment and Suspension (Nonprocurement) establishes non-procurement debarment and suspension regulations, implementing Executive Orders 12549 and 12689.
Finding ref number: 2021-002 Finding caption The District had inadequate internal controls for ensuring compliance with suspension and debarment requirements. Name, address, and telephone of District contact person: Elyssa Louderback, Executive Director of Business & Operations 216 N. G Street Aberdeen, WA 98520 (360) 538-2007 Corrective action the auditee plans to take in response to the finding: The district has been working through a challenging supply chain climate. If we know that we are going to spend over $10,000 in federal funds, we will now look the vendor up in the SAM data base. One of the vendors in question changed ownership and the district did not combine the totals for both vendors to review amounts for suspension and debarment. Anticipated date to complete the corrective action: April, 2022
2020-001
2021-003 The District had inadequate internal controls for ensuring compliance with federal requirements for providing proportional funding to private schools. CFDA Number and Title: 84.425 ? COVID-19 ? Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: 84.425D 120270, 84.425D 130141, 84.425D 120507, and 84.425U 459001 Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. The District spent $1,092,581 of its ESF awards during fiscal year 2021. This included $1,015,396 of its Elementary and Secondary School Emergency Relief (ESSER) Fund subprogram award funded by the Coronavirus Aid, Relief, and Economic Security (CARES) Act (ESSER I), $69,481 of its ESSER subprogram award funded by the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act (ESSER II), and $7,704 of its ESSER subprogram award funded by the American Rescue Plan Act (ARPA) (ESSER III). Federal regulations require award recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding award requirements and monitoring the effectiveness of established controls. Federal regulations also require school districts using ESSER I funds to consult with private schools located within their boundaries and provide their eligible students, teachers and families with equitable services. The amount of federal funding for equitable services must equal the proportion of funds allocated to participating public school attendance areas based on the number of students from low-income families who reside in those attendance areas and attend private schools. Districts must determine the proportional share, which is automatically calculated in the Title I application, before using or transferring program funds. The ESSER I application guides the District to input the proportional share calculated in the Title I application. Description of Condition Our audit found the District?s controls were ineffective for ensuring it used accurate data in its calculation of the proportional share dedicated to private schools. Additionally, the District incorrectly entered the proportional share percentage into the ESSER I application. As a result, the District?s calculation and the amounts allocated to private schools were incorrect. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. This issue was not reported as a finding in the prior audit. Cause of Condition District staff did not understand how to complete the Title I application because of position turnover. Staff did not verify that the income and enrollment data in the Title I application agreed with each applicable section and underlying support. Additionally, the District did not perform a secondary review of the information entered into the Title I application for the equitable share calculation or the information entered into the ESSER I application. Effect of Condition The District?s use of the inaccurate income and enrollment data and incorrect proportional share rate caused it to underallocate private school funding by $4,779, or by 19 percent. Recommendation We recommend the District establish and follow internal controls to ensure: *Staff use accurate income and enrollment data for calculating private schools? proportional share of Title I funding *Accurate data entry into federal grant applications, including performing a secondary review before submitting applications to grantors District?s Response The district included preschool students in the count of eligible students at the elementary school site that hosts that program. This error was compounded by a data entry error. The district submits the Title I application to OSPI for review and approval. The information was not noted as an error through their review. The district appreciates the SAO review and input. Auditor?s Remarks We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 34 CFR, Part 200, Title I ? Improving the Academic Achievement of the Disadvantaged, Subpart A ? Improving Basic Programs Operated by Local Education Agencies, Section 64 ? Factors for determining equitable participation of private school children
Show full finding ▾Hide full finding ▴2021-003 The District had inadequate internal controls for ensuring compliance with federal requirements for providing proportional funding to private schools. CFDA Number and Title: 84.425 ? COVID-19 ? Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: 84.425D 120270, 84.425D 130141, 84.425D 120507, and 84.425U 459001 Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. The District spent $1,092,581 of its ESF awards during fiscal year 2021. This included $1,015,396 of its Elementary and Secondary School Emergency Relief (ESSER) Fund subprogram award funded by the Coronavirus Aid, Relief, and Economic Security (CARES) Act (ESSER I), $69,481 of its ESSER subprogram award funded by the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act (ESSER II), and $7,704 of its ESSER subprogram award funded by the American Rescue Plan Act (ARPA) (ESSER III). Federal regulations require award recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding award requirements and monitoring the effectiveness of established controls. Federal regulations also require school districts using ESSER I funds to consult with private schools located within their boundaries and provide their eligible students, teachers and families with equitable services. The amount of federal funding for equitable services must equal the proportion of funds allocated to participating public school attendance areas based on the number of students from low-income families who reside in those attendance areas and attend private schools. Districts must determine the proportional share, which is automatically calculated in the Title I application, before using or transferring program funds. The ESSER I application guides the District to input the proportional share calculated in the Title I application. Description of Condition Our audit found the District?s controls were ineffective for ensuring it used accurate data in its calculation of the proportional share dedicated to private schools. Additionally, the District incorrectly entered the proportional share percentage into the ESSER I application. As a result, the District?s calculation and the amounts allocated to private schools were incorrect. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. This issue was not reported as a finding in the prior audit. Cause of Condition District staff did not understand how to complete the Title I application because of position turnover. Staff did not verify that the income and enrollment data in the Title I application agreed with each applicable section and underlying support. Additionally, the District did not perform a secondary review of the information entered into the Title I application for the equitable share calculation or the information entered into the ESSER I application. Effect of Condition The District?s use of the inaccurate income and enrollment data and incorrect proportional share rate caused it to underallocate private school funding by $4,779, or by 19 percent. Recommendation We recommend the District establish and follow internal controls to ensure: *Staff use accurate income and enrollment data for calculating private schools? proportional share of Title I funding *Accurate data entry into federal grant applications, including performing a secondary review before submitting applications to grantors District?s Response The district included preschool students in the count of eligible students at the elementary school site that hosts that program. This error was compounded by a data entry error. The district submits the Title I application to OSPI for review and approval. The information was not noted as an error through their review. The district appreciates the SAO review and input. Auditor?s Remarks We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 34 CFR, Part 200, Title I ? Improving the Academic Achievement of the Disadvantaged, Subpart A ? Improving Basic Programs Operated by Local Education Agencies, Section 64 ? Factors for determining equitable participation of private school children
Finding ref number: 2021-003 Finding caption:The District did not have adequate internal controls for ensuring compliance with federal requirements for private schools. Name, address, and telephone of District contact person: Elyssa Louderback, Executive Director of Business & Operations 216 N. G Street Aberdeen, WA 98520 (360) 538-2007 Corrective action the auditee plans to take in response to the finding: The district included preschool students in the count of eligible students at the elementary school site that hosts that program. This error was compounded by a data entry error. The district submits the Title I application to OSPI for review and approval. The information was not noted as an error through their review. The district appreciates the SAO review and input. Anticipated date to complete the corrective action: April, 2022
FAC accepted this audit on August 25, 2021 — management decision was due February 25, 2022.
Aberdeen School District No. 5 September 1, 2019 through August 31, 2020 2020-001 The District?s internal controls are inadequate for ensuring compliance with suspension and debarment requirements. CFDA Number and Title: 10.555 ? National School Lunch Program 10.559 ? COVID-19 ? Summer Food Service Program for Children Federal Grantor Name: U.S. Department of Agriculture (USDA) Federal Award/Contract Number: NA Pass-through Entity Name: Office of the Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: 207WAWA3N1099 Questioned Cost Amount: $0 Description of Condition The District participates in the National School Lunch Program and the COVID-19 ? Summer Food Service Program for Children. The USDA awarded the District $1,773,262 in federal funding to administer these programs during the 2019-20 school year. Federal regulations require recipients to establish and follow internal controls for ensuring compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Grant recipients cannot contract with or purchase from parties suspended or debarred from doing business with the federal government. Whenever the District contracts for goods and services equaling or exceeding $25,000 ? paid all or in part with federal funds ? it must verify the contractor is not suspended, debarred or otherwise excluded. The District may verify a contractor?s status in two ways. First, the District may obtain written certification from the contractor or insert a clause into the contract stating the contractor is not suspended or debarred. Second, the District may review the federal Excluded Parties List System the U.S. General Services Administration issues. The District must meet one of these verification requirements and retain supporting documentation before contracting or purchasing. The District lacked adequate internal controls for verifying the eligibility of one contractor that was paid $46,274 in 2020. We consider this deficiency to be a material weakness that led to material noncompliance with federal requirements. This issue was not reported as a finding in the previous audit. Cause of Condition The District?s normal process is to include suspension and debarment language in contracts. However, the employee responsible for the process did not know a contract was required for the purchase, and as such, did not establish one. As a result, the District did not verify the contractor?s status before making the purchase. Effect of Condition The USDA could recover any federal funds the District paid to ineligible contractors. We verified the contractor was not suspended or debarred. Therefore, we are not questioning the related costs. Recommendation We recommend the District follow its established internal controls for verifying the suspension and debarment status of contractors paid $25,000 or more before contracting or purchasing. District?s Response The person responsible for was not aware that they needed to perform this check. Food Service procurement will be utilizing the same processes as the district purchasing department uses in the future. All vendors will be checked utilizing the SAM database prior to the start of the beginning of the school year. Auditor?s Remarks We appreciate the District?s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regularly scheduled audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 180, OMB, Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement) establishes non-procurement debarment and suspension regulations, implementing Executive Orders 12549 and 12689.
Show full finding ▾Hide full finding ▴Aberdeen School District No. 5 September 1, 2019 through August 31, 2020 2020-001 The District?s internal controls are inadequate for ensuring compliance with suspension and debarment requirements. CFDA Number and Title: 10.555 ? National School Lunch Program 10.559 ? COVID-19 ? Summer Food Service Program for Children Federal Grantor Name: U.S. Department of Agriculture (USDA) Federal Award/Contract Number: NA Pass-through Entity Name: Office of the Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: 207WAWA3N1099 Questioned Cost Amount: $0 Description of Condition The District participates in the National School Lunch Program and the COVID-19 ? Summer Food Service Program for Children. The USDA awarded the District $1,773,262 in federal funding to administer these programs during the 2019-20 school year. Federal regulations require recipients to establish and follow internal controls for ensuring compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Grant recipients cannot contract with or purchase from parties suspended or debarred from doing business with the federal government. Whenever the District contracts for goods and services equaling or exceeding $25,000 ? paid all or in part with federal funds ? it must verify the contractor is not suspended, debarred or otherwise excluded. The District may verify a contractor?s status in two ways. First, the District may obtain written certification from the contractor or insert a clause into the contract stating the contractor is not suspended or debarred. Second, the District may review the federal Excluded Parties List System the U.S. General Services Administration issues. The District must meet one of these verification requirements and retain supporting documentation before contracting or purchasing. The District lacked adequate internal controls for verifying the eligibility of one contractor that was paid $46,274 in 2020. We consider this deficiency to be a material weakness that led to material noncompliance with federal requirements. This issue was not reported as a finding in the previous audit. Cause of Condition The District?s normal process is to include suspension and debarment language in contracts. However, the employee responsible for the process did not know a contract was required for the purchase, and as such, did not establish one. As a result, the District did not verify the contractor?s status before making the purchase. Effect of Condition The USDA could recover any federal funds the District paid to ineligible contractors. We verified the contractor was not suspended or debarred. Therefore, we are not questioning the related costs. Recommendation We recommend the District follow its established internal controls for verifying the suspension and debarment status of contractors paid $25,000 or more before contracting or purchasing. District?s Response The person responsible for was not aware that they needed to perform this check. Food Service procurement will be utilizing the same processes as the district purchasing department uses in the future. All vendors will be checked utilizing the SAM database prior to the start of the beginning of the school year. Auditor?s Remarks We appreciate the District?s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regularly scheduled audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 180, OMB, Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement) establishes non-procurement debarment and suspension regulations, implementing Executive Orders 12549 and 12689.
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Aberdeen School District No. 5 September 1, 2019 through August 31, 2020 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2020-001 Finding caption: The District?s internal controls are inadequate for ensuring compliance with suspension and debarment requirements. Name, address, and telephone of District contact person: Elyssa Louderback, Executive Director of Business & Operations 216 N. G Street Aberdeen, WA 98520 (360) 538-2007 Corrective action the auditee plans to take in response to the finding: The person responsible for was not aware that they needed to perform this check. Food Service procurement will be utilizing the same processes as the district purchasing department uses in the future. All vendors will be checked utilizing the SAM database prior to the start of the beginning of the school year. Anticipated date to complete the corrective action: August 15, 2021
Aberdeen School District No. 5 September 1, 2019 through August 31, 2020 2020-002 The District did not have adequate internal controls for ensuring compliance with federal requirements for eligibility and private schools. CFDA Number and Title: 84.010 ? Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: N/A Questioned Cost Amount: $0 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. During the 2019-20 school year, the District spent $1,637,405 in Title I program funds. Federal regulations require recipients establish and follow internal controls for ensuring compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Eligibility Title I requires participating districts allocate more funds to schools with higher poverty percentages. Districts must rank schools from highest to lowest poverty concentrations based on the total number of students from low-income families attending the school or residing in the area. For districts with 1,000 or more students enrolled, any buildings with a poverty rate higher than 75 percent must be included. The rankings are included in the Title I application, and districts must maintain documentation supporting their rankings. Private Schools Federal regulations require districts using Title I funds to consult with private schools located within their boundaries and provide their eligible students, teachers and families with equitable services. The amount of federal funding set aside for providing equitable services to private school students from low-income families must equal the proportion of funds the District allocates to public school students from low-income families. Districts must determine the proportional share before using or transferring program funds. The proportional share is automatically calculated in the annual Title I application. The share is calculated by multiplying the proportion of private school students from low-income families residing in the area by the District?s total Title 1 allocation. The district must maintain documentation supporting the calculation. Description of Condition Eligibility The District?s internal controls were inadequate for ensuring compliance with eligibility requirements. Specifically, the District used incorrect and unsupported income and enrollment data for ranking and allocating funding to Title I school buildings. Additionally, the District and did not allocate funding to all schools with a poverty rate exceeding 75 percent, as the program requires. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. This issue was not reported as a finding in the prior audit. Private Schools The District?s controls were ineffective for ensuring accurate data were used in its calculation of the proportional share dedicated to private schools. As a result, the District?s calculation and the amount allocated to private schools were incorrect. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. This issue was not reported as a finding in the prior audit. Cause of Condition Eligibility The District had turnover in the position responsible for preparing the Title I application. The enrollment data the District included in the application were from a spreadsheet staff use to reconcile the monthly enrollment report (P-223). However, staff could not explain why the spreadsheet did not reflect data reported in the P-223. Additionally, staff used information for two schools from the previous year?s application to complete the fiscal year 2020 application. As a result, the District excluded one alternative school with full-time students from its rankings and did not allocate another school required funding. Private Schools District staff did not understand how to complete the Title I application because of position turnover. Staff did not verify that the income and enrollment data in the application agreed with each applicable section and underlying support. This oversight resulted in incorrect private school funding allocations. Effect of Condition Eligibility The District cannot demonstrate compliance with federal requirements for allocating Title I funds to eligible schools. Based on corrected income and enrollment data, Miller Junior High incorrectly received more Title I funding per student than four other schools with higher poverty percentages. Additionally, the District did not allocate required funding to J.M. Weatherwax High School, which exceeds the 75 percent poverty rate. Private Schools As a result of the inaccurate income and enrollment data used to calculate private schools? proportional share of Title I funds, the District allocated $5,019 less (16 percent) than required. Additionally, since 1 percent of funds are allocated for parent and family engagement activities, an additional $50 in required funding should have been set aside for private schools. Recommendations We recommend the District establish and follow internal controls for ensuring: ? Correct income and enrollment data are used for determining Title 1 building rankings and funding allocations, and supporting documentation is maintained. ? All eligible schools are included in the Title I building rankings. ? Title I funding is allocated to all schools with poverty rates above 75 percent, as the program requires. ? Accurate income data are used for calculating private schools? proportional share of Title 1 funding. District?s Response Since moving to the CEP program the district has struggled with appropriate identification of the students that were to be counted for eligibility. This information was more concretely provided to the district by OSPI during the audit this year. The district is working with OSPI to correct these issues. In the future, the district will be able to identify the eligible students for district and will work closely with the private schools to identify their eligible students as well. Auditor?s Remarks We appreciate the District?s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regularly scheduled audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 34 CFR, Part 200, Title I ? Improving the Academic Achievement of the Disadvantaged, Subpart A ? Improving Basic Programs Operated by Local Education Agencies, Section 78 ? Allocation of funds to school attendance areas and schools Title 34 CFR, Part 200, Title I ? Improving the Academic Achievement of the Disadvantaged, Subpart A ? Improving Basic Programs Operated by Local Education Agencies, Section 64 ? Factors for determining equitable participation of private school children
Show full finding ▾Hide full finding ▴Aberdeen School District No. 5 September 1, 2019 through August 31, 2020 2020-002 The District did not have adequate internal controls for ensuring compliance with federal requirements for eligibility and private schools. CFDA Number and Title: 84.010 ? Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: N/A Questioned Cost Amount: $0 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. During the 2019-20 school year, the District spent $1,637,405 in Title I program funds. Federal regulations require recipients establish and follow internal controls for ensuring compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Eligibility Title I requires participating districts allocate more funds to schools with higher poverty percentages. Districts must rank schools from highest to lowest poverty concentrations based on the total number of students from low-income families attending the school or residing in the area. For districts with 1,000 or more students enrolled, any buildings with a poverty rate higher than 75 percent must be included. The rankings are included in the Title I application, and districts must maintain documentation supporting their rankings. Private Schools Federal regulations require districts using Title I funds to consult with private schools located within their boundaries and provide their eligible students, teachers and families with equitable services. The amount of federal funding set aside for providing equitable services to private school students from low-income families must equal the proportion of funds the District allocates to public school students from low-income families. Districts must determine the proportional share before using or transferring program funds. The proportional share is automatically calculated in the annual Title I application. The share is calculated by multiplying the proportion of private school students from low-income families residing in the area by the District?s total Title 1 allocation. The district must maintain documentation supporting the calculation. Description of Condition Eligibility The District?s internal controls were inadequate for ensuring compliance with eligibility requirements. Specifically, the District used incorrect and unsupported income and enrollment data for ranking and allocating funding to Title I school buildings. Additionally, the District and did not allocate funding to all schools with a poverty rate exceeding 75 percent, as the program requires. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. This issue was not reported as a finding in the prior audit. Private Schools The District?s controls were ineffective for ensuring accurate data were used in its calculation of the proportional share dedicated to private schools. As a result, the District?s calculation and the amount allocated to private schools were incorrect. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. This issue was not reported as a finding in the prior audit. Cause of Condition Eligibility The District had turnover in the position responsible for preparing the Title I application. The enrollment data the District included in the application were from a spreadsheet staff use to reconcile the monthly enrollment report (P-223). However, staff could not explain why the spreadsheet did not reflect data reported in the P-223. Additionally, staff used information for two schools from the previous year?s application to complete the fiscal year 2020 application. As a result, the District excluded one alternative school with full-time students from its rankings and did not allocate another school required funding. Private Schools District staff did not understand how to complete the Title I application because of position turnover. Staff did not verify that the income and enrollment data in the application agreed with each applicable section and underlying support. This oversight resulted in incorrect private school funding allocations. Effect of Condition Eligibility The District cannot demonstrate compliance with federal requirements for allocating Title I funds to eligible schools. Based on corrected income and enrollment data, Miller Junior High incorrectly received more Title I funding per student than four other schools with higher poverty percentages. Additionally, the District did not allocate required funding to J.M. Weatherwax High School, which exceeds the 75 percent poverty rate. Private Schools As a result of the inaccurate income and enrollment data used to calculate private schools? proportional share of Title I funds, the District allocated $5,019 less (16 percent) than required. Additionally, since 1 percent of funds are allocated for parent and family engagement activities, an additional $50 in required funding should have been set aside for private schools. Recommendations We recommend the District establish and follow internal controls for ensuring: ? Correct income and enrollment data are used for determining Title 1 building rankings and funding allocations, and supporting documentation is maintained. ? All eligible schools are included in the Title I building rankings. ? Title I funding is allocated to all schools with poverty rates above 75 percent, as the program requires. ? Accurate income data are used for calculating private schools? proportional share of Title 1 funding. District?s Response Since moving to the CEP program the district has struggled with appropriate identification of the students that were to be counted for eligibility. This information was more concretely provided to the district by OSPI during the audit this year. The district is working with OSPI to correct these issues. In the future, the district will be able to identify the eligible students for district and will work closely with the private schools to identify their eligible students as well. Auditor?s Remarks We appreciate the District?s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regularly scheduled audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 34 CFR, Part 200, Title I ? Improving the Academic Achievement of the Disadvantaged, Subpart A ? Improving Basic Programs Operated by Local Education Agencies, Section 78 ? Allocation of funds to school attendance areas and schools Title 34 CFR, Part 200, Title I ? Improving the Academic Achievement of the Disadvantaged, Subpart A ? Improving Basic Programs Operated by Local Education Agencies, Section 64 ? Factors for determining equitable participation of private school children
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Aberdeen School District No. 5 September 1, 2019 through August 31, 2020 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2020-002 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal requirements for eligibility and private schools. Name, address, and telephone of District contact person: Elyssa Louderback, Executive Director of Business & Operations 216 N. G Street Aberdeen, WA 98520 (360) 538-2007 Corrective action the auditee plans to take in response to the finding: Since moving to the CEP program the district has struggled with appropriate identification of the students that were to be counted for eligibility. This information was more concretely provided to the district by OSPI during the audit this year. The district is working with OSPI to correct these issues. In the future, the district will be able to identify the eligible students for district and will work closely with the private schools to identify their eligible students as well. Anticipated date to complete the corrective action: August 31, 2021
FAC accepted this audit on May 3, 2020 — management decision was due November 3, 2020.
2019-001 The District did not have adequate internal controls to ensure compliance with the federal requirements for time-and-effort and eligibility documentation. CFDA Number and Title: 84.010 ? Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: N/A Questioned Cost Amount: N/A Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. District school buildings are designated as either schoolwide or targeted assistance programs, depending on poverty levels. During the 2018-19 school year, the District spent $1,179,215 in Title I program funds. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established program controls. Time-and-effort records The District is responsible for ensuring all payroll costs charged to the grant are supported by time-and-effort records, as required by federal regulations and the grantor. Depending on the number and type of activities employees work, time and effort records can take the form of a semi-annual certification or monthly personnel activity report, such as a timesheet. Eligibility Title I requires districts to concentrate higher amounts of funds in schools with higher poverty percentages. To do this, the District is responsible for ranking the schools from highest to lowest concentrations of poverty, and including those rankings in its Title I application. Description of Condition Time-and-effort records We found the District?s internal controls were not effective to ensure it completed accurate time-and-effort records, as required by federal regulations and the grantor. The District did not obtain any time-and-effort records for three employees charged to the grant who worked at the District?s one targeted assistance school totaling $3,451. Further, the costs charged to the grant for five employees who worked in the schoolwide buildings did not match their hours actually worked to the time and effort documents, which totaled $1,372. We consider this deficiency in internal controls to be a material weakness. This issue was reported as a finding in the prior audit as finding 2018-002. Eligibility We found the District?s controls were not effective in ensuring it maintained adequate documentation supporting the District?s rank order of its school buildings based on poverty levels. We consider this deficiency in internal controls to be a material weakness. This issue was not reported as a finding in the prior audit. Cause of Condition Time-and-effort records The District had procedures in place to obtain semi-annual certifications for certificated employees who were included in the schoolwide plan and time and effort records for preschool teachers and counselors. However, the District overlooked obtaining time-and-effort records for certificated employees who worked at its targeted assistance school because they were not included in a schoolwide plan. Further, the District?s review of the time-and-effort records was not thorough enough to catch all errors before charging costs to the grant. Eligibility The District did not maintain copies of the records it used to support its school building rank order for the Title I grant application. The District?s computer system maintains only live data, so it was not possible for the District to generate a new report supporting the poverty numbers by school in the Title I application. Effect of Condition Time-and-effort records The District?s noncompliance with grant requirements could jeopardize future federal funding and might require it to return federal funds to the grantor. By not keeping proper time-and-effort records, the District did not comply with OSPI?s documentation requirements to support costs charged to the federal program. Further, federal grantors cannot be assured the payroll costs charged to the program were accurate and valid. Based on our testing, 27 percent of payroll records lacked sufficient time-and-effort records. For the costs identified in the description of the condition, the District provided alternative records during the audit to support the payroll costs charged to the program, with the exception of $527 of the expenditures tested. The $527 in identified overpayments caused us to project an estimate of $24,369 in overpayments. Without proper documentation supporting the District?s rank order, the District cannot show that it complied with grant requirements and allocated funding from the highest- to lowest-poverty school buildings, as required. Recommendation We recommend the District establish and follow internal controls to ensure it complies with federal and OSPI requirements for time-and-effort records and that it keeps records to demonstrate it properly allocated grant funds to eligible school buildings. District?s Response The district HR and Payroll offices are working more closely to identify and monitor all certificated employees who are funded with Federal Funds to make sure adequate Time & Effort tracking systems are in place. Additionally, the Title I Director will work closely with the Food Service Manager to identify the needed materials for Income verification of students per school site and have that data easily accessible. Auditor?s Remarks We appreciate the District?s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during the next regular audit. Applicable Laws and Regulations The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 U.S. Code Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516 Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, establishes requirements for management of Federal awards to non-Federal entities. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction Addendum to Bulletin 048-17, establishes requirements for documenting time-and-effort. Title 34 CFR, Part 200, Title I ? Improving the Academic Achievement of the Disadvantaged, Subpart A ? ?Improving Basic Programs Operated by Local Education Agencies, Section 78 ? Allocation of funds to school attendance areas and schools
Show full finding ▾Hide full finding ▴2019-001 The District did not have adequate internal controls to ensure compliance with the federal requirements for time-and-effort and eligibility documentation. CFDA Number and Title: 84.010 ? Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: N/A Questioned Cost Amount: N/A Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. District school buildings are designated as either schoolwide or targeted assistance programs, depending on poverty levels. During the 2018-19 school year, the District spent $1,179,215 in Title I program funds. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established program controls. Time-and-effort records The District is responsible for ensuring all payroll costs charged to the grant are supported by time-and-effort records, as required by federal regulations and the grantor. Depending on the number and type of activities employees work, time and effort records can take the form of a semi-annual certification or monthly personnel activity report, such as a timesheet. Eligibility Title I requires districts to concentrate higher amounts of funds in schools with higher poverty percentages. To do this, the District is responsible for ranking the schools from highest to lowest concentrations of poverty, and including those rankings in its Title I application. Description of Condition Time-and-effort records We found the District?s internal controls were not effective to ensure it completed accurate time-and-effort records, as required by federal regulations and the grantor. The District did not obtain any time-and-effort records for three employees charged to the grant who worked at the District?s one targeted assistance school totaling $3,451. Further, the costs charged to the grant for five employees who worked in the schoolwide buildings did not match their hours actually worked to the time and effort documents, which totaled $1,372. We consider this deficiency in internal controls to be a material weakness. This issue was reported as a finding in the prior audit as finding 2018-002. Eligibility We found the District?s controls were not effective in ensuring it maintained adequate documentation supporting the District?s rank order of its school buildings based on poverty levels. We consider this deficiency in internal controls to be a material weakness. This issue was not reported as a finding in the prior audit. Cause of Condition Time-and-effort records The District had procedures in place to obtain semi-annual certifications for certificated employees who were included in the schoolwide plan and time and effort records for preschool teachers and counselors. However, the District overlooked obtaining time-and-effort records for certificated employees who worked at its targeted assistance school because they were not included in a schoolwide plan. Further, the District?s review of the time-and-effort records was not thorough enough to catch all errors before charging costs to the grant. Eligibility The District did not maintain copies of the records it used to support its school building rank order for the Title I grant application. The District?s computer system maintains only live data, so it was not possible for the District to generate a new report supporting the poverty numbers by school in the Title I application. Effect of Condition Time-and-effort records The District?s noncompliance with grant requirements could jeopardize future federal funding and might require it to return federal funds to the grantor. By not keeping proper time-and-effort records, the District did not comply with OSPI?s documentation requirements to support costs charged to the federal program. Further, federal grantors cannot be assured the payroll costs charged to the program were accurate and valid. Based on our testing, 27 percent of payroll records lacked sufficient time-and-effort records. For the costs identified in the description of the condition, the District provided alternative records during the audit to support the payroll costs charged to the program, with the exception of $527 of the expenditures tested. The $527 in identified overpayments caused us to project an estimate of $24,369 in overpayments. Without proper documentation supporting the District?s rank order, the District cannot show that it complied with grant requirements and allocated funding from the highest- to lowest-poverty school buildings, as required. Recommendation We recommend the District establish and follow internal controls to ensure it complies with federal and OSPI requirements for time-and-effort records and that it keeps records to demonstrate it properly allocated grant funds to eligible school buildings. District?s Response The district HR and Payroll offices are working more closely to identify and monitor all certificated employees who are funded with Federal Funds to make sure adequate Time & Effort tracking systems are in place. Additionally, the Title I Director will work closely with the Food Service Manager to identify the needed materials for Income verification of students per school site and have that data easily accessible. Auditor?s Remarks We appreciate the District?s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during the next regular audit. Applicable Laws and Regulations The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 U.S. Code Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516 Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, establishes requirements for management of Federal awards to non-Federal entities. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction Addendum to Bulletin 048-17, establishes requirements for documenting time-and-effort. Title 34 CFR, Part 200, Title I ? Improving the Academic Achievement of the Disadvantaged, Subpart A ? ?Improving Basic Programs Operated by Local Education Agencies, Section 78 ? Allocation of funds to school attendance areas and schools
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Aberdeen School District No. 5 September 1, 2018 through August 31, 2019 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2019-001 Finding caption: The District did not have adequate internal controls to ensure compliance with the federal requirements for time-and-effort and eligibility documentation. Name, address, and telephone of District contact person: Elyssa Louderback, Executive Director of Business & Operations 216 N. G Street Aberdeen WA 98520 (360) 538-2007 Corrective action the auditee plans to take in response to the finding: The district HR and Payroll offices are working more closely to identify and monitor all certificated employees who are funded with Federal Funds to make sure adequate Time & Effort tracking systems are in place. Additionally, the Title I Director will work closely with the Food Service Manager to identify the needed materials for Income verification of students per school site and have that data easily accessible. Anticipated date to complete the corrective action: March 2020
2018-002
FAC accepted this audit on May 19, 2019 — management decision was due November 19, 2019.
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2017-001
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2017-002
FAC accepted this audit on May 15, 2018 — management decision was due November 15, 2018.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on May 14, 2017 — management decision was due November 14, 2017.
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