CORBETT SCHOOL DISTRICT 39

EIN: 936000851

UEI: J5MMM5KLJP43

Data as of August 26, 2026

CORBETT SCHOOL DISTRICT 394 audit years8 findings
4
Audit Years
8
Total Findings
0
Repeat Findings

FY 2025-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on July 9, 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 January 9, 2027 (135 days from today).

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2025-003
Reporting
MATERIAL WEAKNESS

The District did not timely prepare an accurate Schedule of Expenditures of Federal Awards (SEFA). The SEFA provided for audit did not reconcile to the District’s general ledger and contained multiple inaccuracies, including reporting federal expenditures in excess of current-year general ledger activity and misclassification of awards, with certain state programs incorrectly reported as federal programs. Cause: The District lacked effective internal controls over the preparation and review of the Schedule of Expenditures of Federal Awards. Specifically, expenditures reported on the SEFA were not reconciled to the District’s general ledger, and there was no documented review process to verify program classification or reported amounts. Changes in finance staff and the incomplete status of the District’s general ledger at year-end further contributed to the errors and untimely completion of the SEFA. Effect or Potential Effect: Expenditures of federal awards may be reported incorrectly and not be detected and corrected. Because the Auditee’s SEFA was completed incorrectly and not reconciled to the general ledger the SEFA was materially misstated, prior to auditors’ correction recommendations. Questioned Cost: None noted Context: The Schedule of Expenditures of Federal Awards (SEFA) is a required supplementary schedule for Single Audit reporting and is intended to accurately reflect federal award activity in accordance with Uniform Guidance requirements. During the audit, the District provided an initial SEFA that was not timely and contained material inaccuracies. The re-ported expenditures did not reconcile to the District’s general ledger. Certain programs were incorrectly identified as feder-al rather than state awards, and some federal expenditures exceeded amounts recorded in the accounting records. Because the SEFA was neither complete nor accurate at the time of submission, auditors were required to perform addi-tional procedures to identify errors, investigate discrepancies, and propose audit adjustments. Thei extended the audit timeline and increased the risk of noncompliance with federal reporting requirements. Repeat of a Prior-Year Finding: No Recommendation: The District should strengthen internal controls over SEFA preparation by ensuring the general ledger is finalized prior to preparation, reconciling all reported expenditures to accounting records, and implementing a docu-mented review and approval process to verify accuracy and proper program classification. Strengthening procedures, cross training staff, and implementing supervisory review and approval process to verify accuracy, completeness and proper classification of federal versus state awards will enhance compliance with Uniform Guidance, and reduce the risk of future audit findings, and support a more efficient and timely audit process. District’s Response: The District agrees with the finding and recognizes that staffing changes and an incomplete year-end close contributed to the SEFA issues. The District is strengthening reconciliation, review, and oversight procedures to en-sure timely and accurate SEFA reporting in future years. Corrective Action Plan: The District transitioned to a new accounting software for the year ended June 30, 2026. The new system will allow for more clear tracking of individual federal awardS. that are required to be reported on the Schedule of Expenditures of Federal Awards. Additionally, the new business manager for the 2026-2027 fiscal year has multiple years' experience in preparing Schedules of Expenditures of Federal Awards. Planned Implementation Date: August 1, 2026 Responsible Person: District Finance Director

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Finding 2025-003 Accounting for Grants, Schedule of Expenditures of Federal Awards, and Fiscal Man-agement (Material Weakness) Assistance Listing Number and Title: 84.184H Title IV ESEA, School Based Mental Health Name of Federal Agency: U.S. Department of Education Criteria: Per 2 CFR §200.510(b), the auditee must prepare a complete and accurate Schedule of Federal Expenditures (SEFA) for the period covered by the auditee’s financial statements and submit it with the reporting package by the date required by auditors. The SEFA must include total federal awards expended by Assistance Listing (ALN, formerly CFDA), pass-through entity identifying numbers as applicable, the amount provided to subrecipients (if any), and other required disclosures. The SEFA must include all federal expenditures and awards for the year reported and be reconciled to the General Ledger. Condition: The District did not timely prepare an accurate Schedule of Expenditures of Federal Awards (SEFA). The SEFA provided for audit did not reconcile to the District’s general ledger and contained multiple inaccuracies, including reporting federal expenditures in excess of current-year general ledger activity and misclassification of awards, with certain state programs incorrectly reported as federal programs. Cause: The District lacked effective internal controls over the preparation and review of the Schedule of Expenditures of Federal Awards. Specifically, expenditures reported on the SEFA were not reconciled to the District’s general ledger, and there was no documented review process to verify program classification or reported amounts. Changes in finance staff and the incomplete status of the District’s general ledger at year-end further contributed to the errors and untimely completion of the SEFA. Effect or Potential Effect: Expenditures of federal awards may be reported incorrectly and not be detected and corrected. Because the Auditee’s SEFA was completed incorrectly and not reconciled to the general ledger the SEFA was materially misstated, prior to auditors’ correction recommendations. Questioned Cost: None noted Context: The Schedule of Expenditures of Federal Awards (SEFA) is a required supplementary schedule for Single Audit reporting and is intended to accurately reflect federal award activity in accordance with Uniform Guidance requirements. During the audit, the District provided an initial SEFA that was not timely and contained material inaccuracies. The re-ported expenditures did not reconcile to the District’s general ledger. Certain programs were incorrectly identified as feder-al rather than state awards, and some federal expenditures exceeded amounts recorded in the accounting records. Because the SEFA was neither complete nor accurate at the time of submission, auditors were required to perform addi-tional procedures to identify errors, investigate discrepancies, and propose audit adjustments. Thei extended the audit timeline and increased the risk of noncompliance with federal reporting requirements. Repeat of a Prior-Year Finding: No Recommendation: The District should strengthen internal controls over SEFA preparation by ensuring the general ledger is finalized prior to preparation, reconciling all reported expenditures to accounting records, and implementing a docu-mented review and approval process to verify accuracy and proper program classification. Strengthening procedures, cross training staff, and implementing supervisory review and approval process to verify accuracy, completeness and proper classification of federal versus state awards will enhance compliance with Uniform Guidance, and reduce the risk of future audit findings, and support a more efficient and timely audit process. District’s Response: The District agrees with the finding and recognizes that staffing changes and an incomplete year-end close contributed to the SEFA issues. The District is strengthening reconciliation, review, and oversight procedures to en-sure timely and accurate SEFA reporting in future years. Corrective Action Plan: The District transitioned to a new accounting software for the year ended June 30, 2026. The new system will allow for more clear tracking of individual federal awardS. that are required to be reported on the Schedule of Expenditures of Federal Awards. Additionally, the new business manager for the 2026-2027 fiscal year has multiple years' experience in preparing Schedules of Expenditures of Federal Awards. Planned Implementation Date: August 1, 2026 Responsible Person: District Finance Director

Corrective Action Plan

Finding 2025-003 Accounting for Grants, Schedule of Expenditures of Federal Awards, and Fiscal Man-agement (Material Weakness) Assistance Listing Number and Title: 84.184H Title IV ESEA, School Based Mental Health Name of Federal Agency: U.S. Department of Education Criteria: Per 2 CFR §200.510(b), the auditee must prepare a complete and accurate Schedule of Federal Expenditures (SEFA) for the period covered by the auditee’s financial statements and submit it with the reporting package by the date required by auditors. The SEFA must include total federal awards expended by Assistance Listing (ALN, formerly CFDA), pass-through entity identifying numbers as applicable, the amount provided to subrecipients (if any), and other required disclosures. The SEFA must include all federal expenditures and awards for the year reported and be reconciled to the General Ledger. Condition: The District did not timely prepare an accurate Schedule of Expenditures of Federal Awards (SEFA). The SEFA provided for audit did not reconcile to the District’s general ledger and contained multiple inaccuracies, including reporting federal expenditures in excess of current-year general ledger activity and misclassification of awards, with certain state programs incorrectly reported as federal programs. Cause: The District lacked effective internal controls over the preparation and review of the Schedule of Expenditures of Federal Awards. Specifically, expenditures reported on the SEFA were not reconciled to the District’s general ledger, and there was no documented review process to verify program classification or reported amounts. Changes in finance staff and the incomplete status of the District’s general ledger at year-end further contributed to the errors and untimely completion of the SEFA. Effect or Potential Effect: Expenditures of federal awards may be reported incorrectly and not be detected and corrected. Because the Auditee’s SEFA was completed incorrectly and not reconciled to the general ledger the SEFA was materially misstated, prior to auditors’ correction recommendations. Questioned Cost: None noted Context: The Schedule of Expenditures of Federal Awards (SEFA) is a required supplementary schedule for Single Audit reporting and is intended to accurately reflect federal award activity in accordance with Uniform Guidance requirements. During the audit, the District provided an initial SEFA that was not timely and contained material inaccuracies. The re-ported expenditures did not reconcile to the District’s general ledger. Certain programs were incorrectly identified as feder-al rather than state awards, and some federal expenditures exceeded amounts recorded in the accounting records. Because the SEFA was neither complete nor accurate at the time of submission, auditors were required to perform addi-tional procedures to identify errors, investigate discrepancies, and propose audit adjustments. Thei extended the audit timeline and increased the risk of noncompliance with federal reporting requirements. Repeat of a Prior-Year Finding: No Recommendation: The District should strengthen internal controls over SEFA preparation by ensuring the general ledger is finalized prior to preparation, reconciling all reported expenditures to accounting records, and implementing a docu-mented review and approval process to verify accuracy and proper program classification. Strengthening procedures, cross training staff, and implementing supervisory review and approval process to verify accuracy, completeness and proper classification of federal versus state awards will enhance compliance with Uniform Guidance, and reduce the risk of future audit findings, and support a more efficient and timely audit process. District’s Response: The District agrees with the finding and recognizes that staffing changes and an incomplete year-end close contributed to the SEFA issues. The District is strengthening reconciliation, review, and oversight procedures to en-sure timely and accurate SEFA reporting in future years. Corrective Action Plan: The District transitioned to a new accounting software for the year ended June 30, 2026. The new system will allow for more clear tracking of individual federal awardS. that are required to be reported on the Schedule of Expenditures of Federal Awards. Additionally, the new business manager for the 2026-2027 fiscal year has multiple years' experience in preparing Schedules of Expenditures of Federal Awards. Planned Implementation Date: August 1, 2026 Responsible Person: District Finance Director

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FY 2023-06-30

FAC accepted this audit on March 3, 2025 — management decision was due September 3, 2025.

2023-004
Reporting
MATERIAL WEAKNESS

The Schedule of Expenditures of Federal Awards (SEFA) was presented for audit with values that were not reconciled with the general ledger. Cause: The District relied on individuals with insufficient training or support to prepare the SEFA and ensure that it was reconciled with general ledger amounts. District management did not have sufficient training or monitoring policies to recognize and correct the deficiency. Effect or Potential Effect: Errors in recording and reporting of revenues and expenditures of federal awards may not be detected and/or corrected. Because the Auditee’s SEFA that was presented for audit was completed incor-rectly, and not reconciled to the general ledger, the SEFA was materially misstated, prior to auditors’ correction recommendations. Questioned Cost: No Context: Lack of adequate controls over the Schedule of Expenditures of Federal Awards and related accounting resulted in the following: • SEFA was originally presented for auditors with incorrect information. • Inadequate reconciliation between federal expenditures reported on the GL and the SEFA was presented. Repeat of a Prior-Year Finding: No Recommendation: We recommend that the District establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Internal controls should be designed to prevent, detect, or correct errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The District should provide appropriate training to staff who are assigned to prepare and review the SEFA. District’s Response: The District acknowledges the deficiencies. Corrective Action Plan: The District will establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Planned Implementation Date: November 1, 2024 Responsible Person: District Business Manager

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Finding 2023-004 - Accounting for Grants, Schedule of Expenditures of Federal Awards, and Fiscal Manage-ment (Material Weakness) CFDA Title and Number 84.425 Education Stabilization Fund Name of Federal Agency: U.S. Department of Education Criteria: CFR Part 200.508, CFR Part 200.510, Auditee Responsibilities state that the auditee must prepare the Schedule of Expenditures of Federal Awards, which must list individual Federal awards by Federal Agency, in-cluding the total Federal awards expended, name of the pass-through entity, CFDA number, and total amount pro-vided to subrecipients. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial state-ments. Condition: The Schedule of Expenditures of Federal Awards (SEFA) was presented for audit with values that were not reconciled with the general ledger. Cause: The District relied on individuals with insufficient training or support to prepare the SEFA and ensure that it was reconciled with general ledger amounts. District management did not have sufficient training or monitoring policies to recognize and correct the deficiency. Effect or Potential Effect: Errors in recording and reporting of revenues and expenditures of federal awards may not be detected and/or corrected. Because the Auditee’s SEFA that was presented for audit was completed incor-rectly, and not reconciled to the general ledger, the SEFA was materially misstated, prior to auditors’ correction recommendations. Questioned Cost: No Context: Lack of adequate controls over the Schedule of Expenditures of Federal Awards and related accounting resulted in the following: • SEFA was originally presented for auditors with incorrect information. • Inadequate reconciliation between federal expenditures reported on the GL and the SEFA was presented. Repeat of a Prior-Year Finding: No Recommendation: We recommend that the District establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Internal controls should be designed to prevent, detect, or correct errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The District should provide appropriate training to staff who are assigned to prepare and review the SEFA. District’s Response: The District acknowledges the deficiencies. Corrective Action Plan: The District will establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Planned Implementation Date: November 1, 2024 Responsible Person: District Business Manager

Corrective Action Plan

Finding 2023-004 - Accounting for Grants, Schedule of Expenditures of Federal Awards, and Fiscal Management (Material Weakness) CFDA Title and Number 84.425 Education Stabilization Fund Name of Federal Agency: U.S. Department of Education Criteria: CFR Part 200.508, CFR Part 200.510, Auditee Responsibilities state that the auditee must prepare the Schedule of Expenditures of Federal Awards, which must list individual Federal awards by Federal Agency, including the total Federal awards expended, name of the pass-through entity, CFDA number, and total amount provided to subrecipients. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements. Condition: The Schedule of Expenditures of Federal Awards (SEFA) was presented for audit with values that were not reconciled with the general ledger. Cause: The District relied on individuals with insufficient training or support to prepare the SEFA and ensure that it was reconciled with general ledger amounts. District management did not have sufficient training or monitoring policies to recognize and correct the deficiency. Effect or Potential Effect: Errors in recording and reporting of revenues and expenditures of federal awards may not be detected and/or corrected. Because the Auditee’s SEFA that was presented for audit was completed incorrectly, and not reconciled to the general ledger, the SEFA was materially misstated, prior to auditors’ correction recommendations. Questioned Cost: No Context: Lack of adequate controls over the Schedule of Expenditures of Federal Awards and related accounting resulted in the following: • SEFA was originally presented for auditors with incorrect information. • Inadequate reconciliation between federal expenditures reported on the GL and the SEFA was presented. Repeat of a Prior-Year Finding: No Recommendation: We recommend that the District establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Internal controls should be designed to prevent, detect, or correct errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The District should provide appropriate training to staff who are assigned to prepare and review the SEFA. District’s Response: The District acknowledges the deficiencies. Corrective Action Plan: The District will establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Planned Implementation Date: November 1, 2024 Responsible Person: District Business Manager

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FY 2022-06-30

FAC accepted this audit on August 13, 2023 — management decision was due February 13, 2024.

2022-003
Eligibility
MATERIAL WEAKNESS

A material weakness in controls over compliance was identified for controls over compliance requirement E from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility determinations were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the eligibility determination software and processes utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for eligibility determinations could cause ineligible children to receive the subsidy Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 242 eligibility determinations subjected to sampling, 25 samples were selected. Of the 25 eligibility determinations selected, none showed evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all eligibility determinations are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.

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Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement E from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility determinations were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the eligibility determination software and processes utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for eligibility determinations could cause ineligible children to receive the subsidy Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 242 eligibility determinations subjected to sampling, 25 samples were selected. Of the 25 eligibility determinations selected, none showed evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all eligibility determinations are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.

Corrective Action Plan

3. Deficiency 2022-003 ? Material Weakness ? Eligibility Determination a. A material weakness in controls over compliance was identified for controls over compliance requirement E from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility determinations were found not to be implemented. The District should develop and implement policies and procedures to ensure that all eligibility determinations are reviewed in a timely manner and documented appropriately. b. Plan of Action: The District will develop procedures to ensure all eligibility determinations are reviewed timely and documented appropriately by an administrator. c. Timeframe: Beginning August 2023

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2022-004
Procurement & Suspension/Debarment
MATERIAL WEAKNESS

A material weakness in controls over compliance was identified for controls over compliance requirement I(b) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over suspension and debarment determinations were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of checking suspensions and debarments utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for suspension and debarment determinations could cause ineligible vendors to receive payments from federal funds. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 14 vendors paid using Child Nutrition Cluster funds subjected to sampling, 4 samples were selected. Of the 4 vendors selected, none had evidence that the suspension and debarment determinations were reviewed. Recommendation: The District should develop and implement policies and procedures to ensure that all suspension and debarment determinations are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.

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Federal Program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement I(b) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over suspension and debarment determinations were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of checking suspensions and debarments utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for suspension and debarment determinations could cause ineligible vendors to receive payments from federal funds. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 14 vendors paid using Child Nutrition Cluster funds subjected to sampling, 4 samples were selected. Of the 4 vendors selected, none had evidence that the suspension and debarment determinations were reviewed. Recommendation: The District should develop and implement policies and procedures to ensure that all suspension and debarment determinations are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.

Corrective Action Plan

4. Deficiency 2022-004 ? Material Weakness ? Federal Vendor Status Check a. A material weakness in controls over compliance was identified for controls over compliance requirement I(b) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over suspension and debarment determinations were found not to be implemented. The District should develop and implement policies and procedures to ensure that all suspension and debarment determinations are reviewed in a timely manner and documented appropriately. b. Plan of Action: The District is implementing new protocols to ensure vendors receiving federal dollars are appropriately vetted for suspension or debarment, using SAM.gov. c. Timeframe: New protocols are underway to be established for school year 2023-24.

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2022-005
Reporting
MATERIAL WEAKNESS

A material weakness in controls over compliance was identified for controls over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over reporting were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of compiling and submitting reports, as well as difficulties adjusting to process changes related to the pandemic and its effects on the District. Effect or potential effect: A lack of effective internal controls over compliance for reporting could cause incorrect meal numbers to be reported, leading to the district receiving a higher or lower reimbursement than they should have received. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 12 monthly reimbursement reports filed for the year ended June 30, 2022, 4 samples were selected. Of the 4 monthly reimbursement reports, none had evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all monthly reimbursement reports are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding

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Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over reporting were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of compiling and submitting reports, as well as difficulties adjusting to process changes related to the pandemic and its effects on the District. Effect or potential effect: A lack of effective internal controls over compliance for reporting could cause incorrect meal numbers to be reported, leading to the district receiving a higher or lower reimbursement than they should have received. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 12 monthly reimbursement reports filed for the year ended June 30, 2022, 4 samples were selected. Of the 4 monthly reimbursement reports, none had evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all monthly reimbursement reports are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding

Corrective Action Plan

5. Deficiency 2022-005 ? Material Weakness ? Evidence of Review Needed a. A material weakness in controls over compliance was identified for controls over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over reporting were found not to be implemented. The District should develop and implement policies and procedures to ensure that all monthly reimbursement reports are reviewed in a timely manner and documented appropriately. b. Plan of Action: The District will implement internal controls to address the need for additional oversight of monthly meal reimbursement reports. c. Timeframe: August 2023

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2022-006
Eligibility
MATERIAL WEAKNESS

A material weakness in controls over compliance was identified for controls over compliance requirement N.1 from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility verification were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the eligibility verification software and processes utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for eligibility verification could cause ineligible children to receive the subsidy. Questioned costs: No known or estimated questioned costs identified. Context: The 1 eligibility verification performed by the District had no evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all eligibility verifications are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.

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Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement N.1 from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility verification were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the eligibility verification software and processes utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for eligibility verification could cause ineligible children to receive the subsidy. Questioned costs: No known or estimated questioned costs identified. Context: The 1 eligibility verification performed by the District had no evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all eligibility verifications are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.

Corrective Action Plan

6. Deficiency 2022-006 ? Material Weakness ? Eligibility Verification Review a. A material weakness in controls over compliance was identified for controls over compliance requirement N.1 from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility verification were found not to be implemented. The District should develop and implement policies and procedures to ensure that all eligibility verifications are review in a timely manner and documented appropriately. b. Plan of Action: The District will develop procedures to ensure all eligibility verifications are reviewed timely by an administrator and documented appropriately. c. Timeframe: August 2023

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2022-007
Procurement & Suspension/Debarment
MATERIAL WEAKNESS

An instance of noncompliance was identified over compliance requirement I(a) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. The District does not have a documented procurement policy. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with procurement policies and the requirements of receiving and administering federal funding. Effect or potential effect: A lack of a documented procurement policy for purchases using federal funds could cause a contract or purchase to be made in an improper manner. Questioned costs: No known or estimated questioned costs identified. Context: There were 245 nonpayroll expenditures, totaling $205,924.67, that were made by the District without a documented procurement policy. Recommendation: The District should develop and implement a formal procurement policy consistent with Federal, State, and local laws and regulations. Views of responsible officials: The District understands and concurs with this finding.

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Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.318 (a), a non-Federal entity must "have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327.? Condition: An instance of noncompliance was identified over compliance requirement I(a) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. The District does not have a documented procurement policy. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with procurement policies and the requirements of receiving and administering federal funding. Effect or potential effect: A lack of a documented procurement policy for purchases using federal funds could cause a contract or purchase to be made in an improper manner. Questioned costs: No known or estimated questioned costs identified. Context: There were 245 nonpayroll expenditures, totaling $205,924.67, that were made by the District without a documented procurement policy. Recommendation: The District should develop and implement a formal procurement policy consistent with Federal, State, and local laws and regulations. Views of responsible officials: The District understands and concurs with this finding.

Corrective Action Plan

7. Deficiency 2022-007 ? Instance of Noncompliance ? Procurement Policy a. An instance of noncompliance was identified over compliance requirement 1(a) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. The District does not have a documented procurement policy. The District should develop and implement a formal procurement policy consistent with Federal, State, and local laws and regulations. b. Plan of Action: The District will undertake a review of best practices regarding procurement policy and will advance resulting recommendations. c. Timeframe: Fiscal year 2023-24

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2022-008
Other
MATERIAL WEAKNESS

An instance of noncompliance was identified over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Recordkeeping of the daily supporting documentation for the monthly claims was found to not be in compliance with federal requirements. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of compiling and submitting reports, as well as difficulties adjusting to process changes related to the pandemic and its effects on the District. Effect or potential effect: A lack of proper recordkeeping over the number of meals reported for the Child Nutrition Cluster could cause incorrect meal numbers to be reported, causing an over or under claim on reimbursement. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 12 monthly reimbursement reports filed for the year ended June 30, 2022, 4 samples were selected. Of the 4 monthly reimbursement reports, all were supported by daily consolidation sheets, but those sheets did not have the original tally sheets available as support. Recommendation: The District should develop and implement policies and procedures to ensure that all original daily meal counts and tallies used to support reimbursement reports are maintained for the appropriate amount of time. Views of responsible officials: The District understands and concurs with this finding.

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Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 7, Subtitle B, Chapter II, Subpart A, Section 210.8 (a).5, a school food authority must "maintain on file, each month's Claim for Reimbursement and all data used in the claims review process, by school. Records shall be retained as specified in ? 210.23(c) of this part." Condition: An instance of noncompliance was identified over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Recordkeeping of the daily supporting documentation for the monthly claims was found to not be in compliance with federal requirements. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of compiling and submitting reports, as well as difficulties adjusting to process changes related to the pandemic and its effects on the District. Effect or potential effect: A lack of proper recordkeeping over the number of meals reported for the Child Nutrition Cluster could cause incorrect meal numbers to be reported, causing an over or under claim on reimbursement. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 12 monthly reimbursement reports filed for the year ended June 30, 2022, 4 samples were selected. Of the 4 monthly reimbursement reports, all were supported by daily consolidation sheets, but those sheets did not have the original tally sheets available as support. Recommendation: The District should develop and implement policies and procedures to ensure that all original daily meal counts and tallies used to support reimbursement reports are maintained for the appropriate amount of time. Views of responsible officials: The District understands and concurs with this finding.

Corrective Action Plan

8. Deficiency 2022-008 ? Instance of Noncompliance ? Meal County Tally a. An instance of noncompliance was identified over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Recordkeeping of the daily supporting documentation for the monthly claims was found to not be in compliance with federal requirements. The District should develop and implement policies and procedures to ensure that all original daily meal counts and tallies used to support reimbursement reports are maintained for the appropriate amount of time. b. Plan of Action: The District will review, develop and implement procedures to provide the required reporting. c. Timeframe: Fiscal year 2023-24

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