Columbia School District No. 400

2021-001 The District did not have adequate internal controls for ensuring compliance with federal requirements for time-and-effort documentation and standardized test security.CFDA Number and Title: 84.010 Title I Grants to Local Education AgenciesFederal Grantor Name: Department of EducationFederal Award/Contract Number:Pass-through Entity Name: Office of Superintendent of PublicInstruction (OSPI)Pass-through Award/Contract Number: 0203811 and 0270922Questioned Cost Amount: $33,642BackgroundThe objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting academic standards and who reside in areas with high concentrations of children from low-income families. The District spent $286,073 in federal funds for its Title I program during fiscal year 2021. Employee salaries and benefits made up about 85 percent of program expenditures.Federal regulations require recipients of federal awards to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established program controls.Time-and-effort documentationThe District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as federal regulations and the awarding agency require. Depending on the number and type of activities employees perform, time-and-effort documentation can be a semi-annual certification or monthly personnel activity report, such as a detailed timesheet.If the District initially allocates payroll expenditures to federal programs based on budgeted or estimated time or amounts, then payroll and time-and-effort records must be compared at least quarterly and adjusted if the difference is 10 percent or more. At year-end, payroll records must match time-and-effort documentation to ensure federal programs are charged only for work directly supporting them.Standardized test securityStates, in consultation with school districts, must establish and maintain an assessment system that is valid, reliable and consistent with relevant professional and technical standards. States must have formal, well-documented policies and procedures to maintain test security and ensure that districts implement these policies and procedures for all standardized tests. OSPI provides templates for all districts to document their Test Security and Building Plans (TSBP) for each assessment that districts administer. This serves as a district?s written policies and procedures. The template contains a link to detailed guidance as well as other templates for staff who attend required training and staff assurances for test security. These templates also provide assurance that school districts are following the prescribed requirements and understand any new requirements.Description of ConditionTime-and-effort documentationThe District?s controls were not effective for ensuring it obtained adequate time-and-effort documentation for two employees who worked part-time in the program. The District did not have time-and-effort documentation for one employee showing actual hours worked and activities performed to support what the District charged to the program. Another employee?s time-and-effort documentation did not reflect actual hours worked to support the percentage of payroll costs the District charged to the program.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 audit.Standardized test securityThe District?s controls were not effective to comply with this requirement. The District did not complete or retain its TSBP or other testing documentation for all standardized tests it administered, as OSPI requires. During the fiscal year, the District administered the English Language Proficiency Assessment (ELPA) screener assessment and ELPA 21.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 audit.Cause of ConditionTime-and-effort documentationDistrict staff did not dedicate the necessary time and resources to ensure it met all Title I requirements and retained all supporting documentation. District staff said they did not know about the requirement for administrative employees to complete time-and-effort documentation to support the employee?s time charged to the program. District staff also did not perform an adequate review of time-and-effort documentation to ensure accuracy.Standardized test securityThe District experienced turnover in the key position responsible for completing and retaining the Test Security and Building Plans (TSBP) and the standardized testing documentation.Effect of Condition and Questioned CostsTime-and-effort documentationWithout proper time-and-effort records, federal grantors cannot be sure that payroll costs charged to the program were accurate and valid. We tested seven employees whose salaries and benefits make up about 99 percent of total payroll expenditures charged to the program. We found the District did not obtain time-and-effort documentation for one employee and could not support payroll costs of $33,642 charged to the federal program as OSPI requires. Therefore we are questioning these costs.We found another employee?s time-and-effort documentation did not reflect actual hours worked in the program to support payroll costs of $11,988 charged to the program. During the audit, the District provided alternative documentation demonstrating the employee worked 40-percent of their time in the program, which supported the District?s percentage used, and the costs charged to the program were for allowable activities. Therefore, we are not questioning these costs.Standardized test securityWithout a written TSBP and the testing documentation, the District cannot demonstrate it implemented and complied with all of OSPI?s assessment security requirements while conducting standardized tests.RecommendationWe recommend the District establish and follow internal controls for ensuring it complies with federal and OSPI requirements for time-and-effort documentation and assessment system security. Specifically, we recommend the District:? Obtain all time-and-effort documentation and review the documentation to ensure time reported agrees to actual hours worked in the program for all Title I staff and supports payroll costs charged to the program, as OSPI requires.? Complete and retain a written TSBP and the testing documentation for all standardized tests administered, as OSPI requires.District?s ResponseBased on the finding, Columbia School District will engage in the following plan to ensure that internal controls ensure compliance with federal requirements for time-and-effort documentation and standardized test security.Time-and-Effort:1. Time and effort will be maintained as per federal regulations and the awarding agency requirements.2. Columbia School District will continue to document time and effort using monthly timecards and personnel action forms.3. Timecards will be based on personnel action forms4. Personnel action forms will be updated by the program supervisor or admin designee at the time of hire, and any time a change in the program occurs.5. At the time of hire, and at least annually, the personnel action forms will be reviewed by both the program supervisor, business manager, and payroll specialist annually to ensure that there are no discrepancies between the Personnel action form and timecards.Standardized Test Security:1. Each year, the District Test Coordinator will complete the TSBP. This plan will be reviewed by the Central Office Administrators and will be retained at Columbia School district and available for audit, according to the district retention policy2. The District Test Coordinator in Columbia School District will ensure that Test Security Staff Assurance Reports are completed as required by OSPI. Test Security Staff Assurance Reports will be retained at Columbia School District and available for audit, according to the district retention policy.3. Prior to and after each testing window, the Special Programs Administrator or another admin designee will review the TSBP and Test Security Staff Assurance Reports with the District Test Coordinator to ensure that all required reports are completed and retained as required.Auditor?s RemarksWe appreciate the District?s commitment to resolving the issues noted and will follow up during the next scheduled audit.Applicable Laws and RegulationsTitle 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.Time-and-effort documentationTitle 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.Standardized test securityTitle 20 U.S. Code section 6311(b)(2)(B)(iii) requires state and local education agencies to establish and maintain valid and reliable assessment systems, consistent with relevant professional and technical standards.