MARYSVILLE SCHOOL DISTRICT 25Local Government

2025-002 The District did not have adequate internal controls and did not comply with time-and-effort requirements. Assistance Listing Number and Title: 21.027 COVID-19 – Coronavirus State and Local Fisal Recovery Funds Federal Grantor Name: U.S. Department of the Treasury Federal Award/Contract Number: N/A Pass-through Entity Name: Snohomish County Pass-through Award/Contract Number: BH-23-AR-08-050, EL-22-AR-050 Known Questioned Cost Amount: $0 Prior Year Audit Finding: Yes, Finding 2024-002 Background During fiscal year 2025, the District spent $513,574 in federal funds from the Coronavirus State and Local Fiscal Recovery Funds program to provide student support advocates, social emotional learning support and early learning services. The objective of the program is to respond to the COVID-19 pandemic’s negative effects on public health and the economy, provide premium pay to essential workers during the pandemic, provide government services to the extent COVID-19 caused a reduction in revenues collected and make necessary investments in water, sewer or broadband infrastructure. 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 time sheet. 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 the Office of the Superintendent of Public Instruction (OSPI) require. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. Cause of Condition District staff did not dedicate the necessary time and resources to ensure time charged to the program was supported with time-and-effort documentation. District staff misunderstood OSPI’s time-and-effort requirements and either did not complete time-and-effort documentation for some employees or prepared and had employees sign PARs semiannually rather than monthly, as required. The District relied on one staff member to identify employees requiring time-and-effort certifications without a secondary review to ensure their determinations were complete and complied with grant requirements. Effect of Condition The District did not obtain time and effort documentation for three employees for the first semester whose payroll costs charged to the program totaled $108,346. In addition, four monthly PARs we tested, with payroll costs charged to the program totaling $27,696, were prepared and signed at the end of the semester (June 2025) rather than monthly after the work was performed as required. Without adequate and timely time-and-effort documentation, the District cannot demonstrate compliance with OSPI’s documentation requirements to 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 supported these payroll costs by providing alternative documentation to show the three employees worked on the program. In addition, although four PARs were not prepared and signed monthly as required, the District obtained those certifications by the end of June 2025. Therefore, we are not questioning these costs. Recommendation We recommend the District design, implement and follow internal controls to ensure it complies with federal and OSPI requirements for obtaining time-and-effort documentation timely. District’s Response The District agrees with the finding and recognizes the need to strengthen internal controls and update procedures related to time-and-effort documentation to align with current federal and OSPI guidance, including OSPI Bulletin 039-24 and related federal grant requirements. To address this finding, the District will conduct a comprehensive review of all federal grant-funded positions and applicable time-and-effort requirements. This review will include evaluating available documentation methods authorized by OSPI, including semi-annual certifications, monthly personnel activity reports (PARs), and fixed schedule systems where appropriate. The District will also revise written procedures, establish clearer internal review protocols, and implement additional oversight to ensure required certifications and documentation are completed timely and maintained appropriately. 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, Time and Effort (T&E) Reporting establishes requirements for documenting time-and-effort, including fixed schedule systems.

2025-003 The District did not have adequate internal controls and did not comply 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: GT-02572, GT-HNI25-0062, and GT-03180 Known Questioned Cost Amount: $1,582 Prior Year Audit Finding: N/A Background During fiscal year 2025, the District spent $2,676,178 in federal funds from the Special Education program cluster. 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, 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 time sheet. Time-and-effort documentation must 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 the Office of the Superintendent of Public Instruction (OSPI) require. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. Cause of Condition District staff did not dedicate the necessary time and resources to ensure time charged to the program was supported with time-and-effort documentation. District staff misunderstood OSPI’s time-and-effort requirements and prepared and had employees sign PARs semiannually rather than monthly, as required. Additionally, District staff incorrectly assumed substitute time worked on the program did not require time-and-effort documentation. The District relied on one staff member to identify employees requiring time-and-effort certifications without a secondary review to ensure their determinations were complete and complied with grant requirements. Effect of Condition and Questioned Costs Using a nonstatistical sample, we found noncompliance with five out of 11 employees and substitutes (45.5%) tested. Specifically: • Two substitutes whose salaries and benefits totaled $12,083 were not supported by time-and-effort documentation • The PARs for two employees, with payroll costs charged to the program totaling $68,355, were prepared and signed at the end of the semesters (March and June 2025) rather than monthly after the work was performed as required • One employee did not work on Special Education activities but their payroll costs of $1,582 were miscoded and charged to the program. We are questioning these costs. Based on the projection of our sample, we estimate $6,904 in overpayments Separately, outside of our sample, we identified two substitutes whose salaries and benefits totaled $7,522 that were not supported by time-and-effort documentation as required. Without adequate and timely time-and-effort documentation, the District cannot demonstrate compliance with OSPI’s documentation requirements to 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 supported these payroll costs by providing alternative documentation to show the four substitutes worked on the program. In addition, although the PARs for two employees were not prepared and signed monthly as required, the District obtained signed certifications at the end of each semester during the school year. Therefore, we are not questioning these costs. Federal regulations require the State Auditor’s Office to report known and likely questioned costs that are more than $25,000 for each type of compliance requirement. We question costs when we find the District does not have adequate documentation to support expenditures. Recommendation We recommend the District design, implement and follow internal controls to ensure it complies with federal and OSPI requirements for obtaining time-and-effort documentation timely. District’s Response The District agrees with the finding and recognizes the need to strengthen internal controls and update procedures related to time-and-effort documentation to align with current federal and OSPI guidance, including OSPI Bulletin 039-24 and related federal grant requirements. To address this finding, the District will conduct a comprehensive review of all federal grant-funded positions and applicable time-and-effort requirements. This review will include evaluating available documentation methods authorized by OSPI, including semi-annual certifications, monthly personnel activity reports (PARs), and fixed schedule systems where appropriate. The District will also revise written procedures, establish clearer internal review protocols, and implement additional oversight to ensure required certifications and documentation are completed timely and maintained appropriately. 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 the Superintendent of Public Instruction Bulletin 039-24, Time and Effort (T&E) Reporting establishes requirements for documenting time-and-effort, including fixed schedule systems.

2025-004 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 the Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: GT-03590, GT-03815, GT-03713, GT-03995, GT-02373 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 academic standards and reside in areas with high concentrations of children from low-income families. During the 2024-25 school year, the District spent $3,054,328 in federal funds from Title I. 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 time sheet. 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 the Office of the Superintendent of Public Instruction (OSPI) require. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. Cause of Condition District staff did not dedicate the necessary time and resources to ensure time charged to the program was supported with time-and-effort documentation. District staff misunderstood OSPI’s time-and-effort requirements and either did not complete time-and-effort documentation for some employees or prepared and had employees sign PARs semiannually rather than monthly, as required. Additionally, District staff incorrectly assumed substitute time worked on the program did not require time-and-effort documentation. The District relied on one staff member to identify employees requiring time-and-effort certifications without a secondary review to ensure their determinations were complete and complied with grant requirements. Effect of Condition Using a nonstatistical sample, we tested 22 employees and substitutes and found three substitutes (13.6%) whose salaries and benefits totaled $1,246, were not supported by required time-and-effort documentation. We also found the PARs for one employee whose salary and benefits totaled $8,168, were prepared and signed each semester rather than monthly after the work was performed as required. Separately, outside of our sample, we identified 14 employees and substitutes whose salaries and benefits totaling $185,546 were not supported by time-and-effort documentation as required. Without adequate and timely time-and-effort documentation, the District cannot demonstrate compliance with OSPI’s documentation requirements to 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 supported these payroll costs by providing alternative documentation to show the 17 employees and substitutes worked on the program. In addition, although the PARs for one employee were not prepared and signed monthly as required, the District obtained signed certifications by the end of June 2025. Therefore, we are not questioning these costs. Recommendation We recommend the District design, implement and follow internal controls to ensure it complies with federal and OSPI requirements for obtaining time-and-effort-documentation timely. District’s Response The District agrees with the finding and recognizes the need to strengthen internal controls and update procedures related to time-and-effort documentation to align with current federal and OSPI guidance, including OSPI Bulletin 039-24 and related federal grant requirements. To address this finding, the District will conduct a comprehensive review of all federal grant-funded positions and applicable time-and-effort requirements. This review will include evaluating available documentation methods authorized by OSPI, including semi-annual certifications, monthly personnel activity reports (PARs), and fixed schedule systems where appropriate. The District will also revise written procedures, establish clearer internal review protocols, and implement additional oversight to ensure required certifications and documentation are completed timely and maintained appropriately. 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 to Bulletin 039-24, Time and Effort (T&E) Reporting establishes requirements for documenting time-and-effort, including fixed schedule systems.

2024-002 The District did not have adequate internal controls and did not comply with time-and-effort requirements. Assistance Listing Number and Title: 21.027 COVID 19 – Coronavirus State and Local Fiscal Recovery Funds Federal Agency Name: U.S. Department of the Treasury Federal Award/Contract Number: N/A Pass-through Entity Name: Snohomish County Pass-through Award/Contract Number: BH-23-AR-08-050 & EL-22-AR-22-050 Known Questioned Cost Amount: $0 Prior Year Audit Finding: N/A Background During the 2023-2024 school year, the District spent $740,931 in federal funds from the Coronavirus State and Local Fiscal Recovery Funds program to provide student support advocates, social emotional learning support and early learning services. The objective of the program is to respond to the COVID-19 pandemic’s negative effects on public health and the economy, provide premium pay to essential workers during the pandemic, provide government services to the extent COVID-19 caused a reduction in revenues collected and make necessary investments in water, sewer or broadband infrastructure. Federal regulations require recipients to establish and maintain 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 charged to the program with adequate time-and-effort documentation, as required by federal regulations and the Office of Superintendent of Public Instruction (OSPI), the cognizant agency for school districts. 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, 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 require. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. Cause of Condition District staff responsible for collecting time-and-effort documentation relied on staff assignments and budget allocations established for the fiscal year to identify employees requiring time-and-effort documentation. During the year, the District had staffing changes and decided to charge payroll costs for three employees to the federal program. Staff responsible for obtaining time-and-effort forms did not identify these staff assignment changes when performing their review and did not collect the time-and-effort documentation as required. Effect of Condition The District did not obtain time-and-effort documentation for three employees whose salaries and benefits costs totaling $81,201 it charged to the program. Without adequate time-and-effort documentation, the District cannot demonstrate compliance with OSPI’s documentation requirements to 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 supported these payroll costs by providing alternative documentation to show the employees worked on 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 understands the importance of internal controls regarding time and effort reporting using federal funds. The district has implemented stronger internal controls in order to reconcile and comply with federal and OSPI time and effort requirements. 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 regular 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, Guidelines for Charging Employee Compensation to Federal Grants establishes requirements for documenting time-and-effort, including fixed schedule systems.

2023-002 The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, and restricted purpose requirements. Assistance Listing Number and Title: 32.009, COVID-19 Emergency Connectivity Fund Program Federal Grantor Name: Federal Communications Commission Federal Award/Contract Number: ECF202204286 Pass-through Entity Name: N/A Pass-through Award/Contract Number: N/A Known Questioned Cost Amount: $2,188,153 Prior Year Audit Finding: Yes, Finding 2022-002 Background The Emergency Connectivity Fund (ECF) Program provides funding to meet the needs of students and school staff who would otherwise lack access to connected devices and broadband connections sufficient to engage in remote learning. This is referred to as “unmet need.” In fiscal year 2023, the District spent $2,188,153 in ECF Program funds to purchase laptops for students. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. Allowable activities and costs ECF Program recipients may only seek reimbursement for eligible devices and services provided to students and staff with unmet need. Recipients are prohibited from seeking reimbursement for eligible equipment and services used solely at the school or held for future use (in other words, warehousing). Restricted purpose – unmet need When submitting applications to the Federal Communications Commission (FCC), schools only had to provide an estimate of their students’ and staff’s unmet need. However, when requesting reimbursement, the District could only request program funds for eligible equipment and services provided to students and school staff with actual unmet need. Description of Condition Allowable activities and costs/restricted purpose – unmet need The District estimated the unmet need for eligible equipment when it applied for ECF Program funds. However, our audit found the District’s internal controls were ineffective for ensuring it documented the determination of actual unmet need and only requested reimbursement for equipment provided to students. Specifically, the District purchased 5,359 laptops based on its estimate of unmet need, and it requested reimbursement for these purchases totaling $2,188,153. However, the District did not maintain documentation showing it provided each laptop paid with program funds to a student with unmet need. In addition, the District held 553 of the 5,359 laptops for future use. Cause of Condition Allowable activities and costs/restricted purpose – unmet need As communicated in the prior audit finding, the District staff thought the determination of unmet need provided during the application process was sufficient to comply with this requirement. Since the funding spanned two fiscal years, the District had already requested reimbursement before the prior audit identified this issue. The District did not take any additional action and is waiting for audit resolution from the federal grantor. Effect of Condition and Questioned Costs Allowable activities and costs/restricted purpose – unmet need Because the District did not have documentation supporting whether it provided eligible equipment to students with actual unmet need, it cannot demonstrate compliance with the program’s requirements. Given the nature of the program and circumstances, it is likely that at least some of the equipment the District charged to the award addressed unmet needs. However, the lack of a documented assessment of students’ actual unmet need means that all costs are unsupported. Since we do not have a reasonable basis for estimating how much of the District’s expenditures are allowable, we are questioning all unsupported costs. Federal regulations require the Office of the Washington State Auditor to report known questioned costs that are greater than $25,000 for each type of compliance requirement. We question costs when we find the District does not have adequate documentation to support expenditures. Recommendation We recommend the District work with the awarding agency to determine audit resolution. We further recommend the District establish and follow internal controls to ensure staff fully understand the requirements for ECF awards. Specifically, the District should request reimbursement only for eligible equipment provided to students with unmet need and maintain documentation demonstrating compliance. District’s Response Marysville School District does not concur with the audit finding being issued by the State Auditors’ Office. The funds granted by the Federal Communications Commission in the midst of the COVID-19 pandemic were for Emergency Connectivity to ensure students and staff had access to devices sufficient for remote learning. A component of the funding is to only seek support for eligible equipment provided to students and school staff who would otherwise lack access to connected devices sufficient to engage in remote learning. When it comes to making this determination of unmet need, the FCC explains that “we think that schools are in the best position to determine whether their students and staff have devices and broadband services sufficient to meet their remote learning needs, and we recognize that they are making such decisions in the midst of the pandemic. We, therefore, will not impose any specific metrics or process requirements on those determinations”. Due to the complexities of providing a sufficient education that includes aspects of remote education, the District determined that only District issued devices with preloaded applications and security was sufficient to facilitate remote activities. Since the Marysville School District did not have enough devices for students and staff that would need them for remote learning, the “unmet need” is obvious. Marysville School District determined that it was necessary for all students, teachers, and paraeducators to have a district issued device in order to meet the increased challenges of providing safe and equitable access to education to all students during an ongoing pandemic and state of emergency. Remote learning required district students/staff to use district devices for various reasons including: • Instruction: access to curriculum, supplemental resources, and required software through district licenses. • Support: the ability for technology staff to provide direct technical support through remote access. • State Requirements: meeting state testing requirements, such as SBA which cannot be completed on a personal device. • Safety and Security: implementing web filtering to ensure safe browsing, content monitoring for timely student and staff intervention and support and gave districts the ability to automatically authenticate student accounts to further prevent Zoom bombings. • Equity: ensuring every student had the same level of access and provided access to accessibility tools not available on personal devices. Before the pandemic, our district's student and staff laptops were not prepped for at-home learning scenarios and thousands were aging out of their life cycle. Recognizing the unpredictable nature of the pandemic and the potential for a sudden shift back to remote learning at any time, transitioning to a one-to-one student to district issued device ratio was determined to be a critical unmet need in the Marysville School District. In addition, to maintain equitable access to education, devices that were not individually assigned were prepared and available for immediate distribution for the following: if a device were broken and needed replacing or if a student forgot their district device at home or if a rapid return to remote learning was required. We appreciate the funding and assistance to meet our student needs in the midst of the pandemic and we do not take lightly our obligation to follow the established rules and guidance available to us. Based on the information outlined above, we feel strongly that we have fully accomplished that obligation. We have accounted for all our devices and have fulfilled the responsibility of determining the unmet needs of our students. We therefore do not believe that any of the $2,188,153 in costs is in question and do not concur with the issued audit finding. Auditor’s Remarks The State Auditor’s Office is sympathetic to the significant challenges the District faced during the COVID-19 pandemic, and deeply respects its commitment to student learning despite these challenges. The State Auditor’s Office knows that in many cases, governments across Washington received significant pandemic-era federal funds without also receiving clear guidance on how to use them. Then, and now, the State Auditor’s Office continues to advocate for clear, timely guidance from federal agencies to make sure Washington governments are not put in a difficult position at audit time. However, when auditing federal programs of any kind, governments must provide documentation to substantiate that they met the award requirements. As is our practice and audit standards require, we will review the status of this finding during our next audit. We value our partnership with the District in striving for transparency in public service. 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 47 CFR Part 54, Universal Service, Subpart Q, Emergency Connectivity Fund, describes the ECF Program requirements.

See Schedule of Findings and Questioned Costs for chart/table

See Schedule of Findings and Questioned Costs for chart/table

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