OAKLAND UNIFIED SCHOOL DISTRICTState Government

2023-001 Twenty-First Century Attendance Reporting A material weakness in internal control and material noncompliance with attendance reporting Code 50000. Federal Program Affected U.S. Department of Education, California Department of Education: Twenty-First Century Community Learning Centers, 84.287. Criteria The California Department of Education (CDE) administers California's 21st Century Community Learning Centers CCLC) program. Education Code sections 8484.7 ‐ 8484.9 further define California's 21st CCLC Program. This state‐administered, federally funded program provides five‐year grant funding to establish or expand before and after-school programs that provide disadvantaged kindergarten through twelfth‐grade students with academic enrichment opportunities and supportive services to help the students meet state and local standards in core content areas. The District evidences student participation by reporting attendance to the CDE. The daily attendance is recorded for all the students attending the after-school program on each school day the program operates. Condition We sampled six schools and compared the attendance record for the entire school year from the Aeries attendance system to the CDE report. We identified errors in two schools for the attendance reported to the CDE. Questioned Costs Not applicable. Context The District operates a 21 Century Program at ten schools. We haphazardly selected a sample of six schools to test all twelve months for fiscal year ended June 30, 2023, and the condition applies to two of the sampled schools. The observed error rates were 27.6% and 17.2% at those two schools. Cause In response to prior audit findings, the District transitioned to a new attendance accounting system for the after-school program during the year. Although management of the District expects the new system will ultimately increase the accuracy the attendance reporting, there were challenges as the system was new this year. Recommendation We recommend that the District continue implementing its new attendance accounting system for the after-school program. Lessons learned from the year of implementation should be used to improve the process going forward. Views of Responsible Officials Management agrees. See separately issued Corrective Action Plan. Identification as a Repeat Finding See finding 2022-006.

Criteria The California Department of Education (CDE) administers California's 21st Century Community Learning Centers CCLC) program. Education Code sections 8484.7 - 8484.9 further define California's 21st CCLC Program. This state-administered, federally funded program provides five-year grant funding to establish or expand before and after-school programs that provide disadvantaged kindergarten through twelfth-grade students with academic enrichment opportunities and supportive services to help the students meet state and local standards in core content areas. The District evidences student participation by reporting attendance to the CDE. The daily attendance is recorded for all the students attending the after-school program on each school day the program operates. Condition There was a material weakness in internal control over compliance and noncompliance because we identified errors in the attendance reported to the CDE. Questioned Costs Not applicable. Context The District operates a 21 Century Program at ten schools. We selected a sample of five schools, and the condition applies to three of the sampled schools. The observed error rates were 6.9%, 1.2%, and 10.9%. Cause In response to prior audit findings, the District transitioned to a new attendance accounting system for the afterschool program during the year. Although management of the District expects the new system will ultimately increase the accuracy the attendance reporting, there were challenges as the system was new this year.Recommendation We recommend that the District continue implementing its new attendance accounting system for the afterschool program. Lessons learned from the year of implementation should be used to improve the process going forward. Views of Responsible Officials/Corrective Action Plan OUSD has implemented a new Expanded Learning Attendance improved tracking system and provided training to service providers. This new database allows for accurate and prompt attendance taking. 1. OUSD transitioned to a new attendance tracking system. Due to the multiple errors and consistent changes in attendance, OUSD began using Aeries Supplemental Attendance tracking instead of CitySpan in fall 2021. This transition has allowed the Expanded Learning Office to support struggling sites with real-time accurate attendance data. 2. On July 29, OUSD held a mandatory Aeries training for all after-school staff and reviewed all CDE (ASES, 21st CCLC, and ASSETS) attendance requirements. Over 100 after-school staff attended. 3. All Attendance documents were revised to include Aeries attendance protocols. 4. OUSD Designed dashboards with real-time student and attendance data for all after-school providers The CDE has accepted the District's CAP as of 8/29/2022, and it we expect improved outcome during the fiscal year 2023.

Criteria The California Department of Education (CDE) administers California's 21st Century Community Learning Centers CCLC) program. Education Code sections 8484.7 - 8484.9 further define California's 21st CCLC Program. This state-administered, federally funded program provides five-year grant funding to establish or expand before and after school programs that provide disadvantaged kindergarten through twelfth-grade students with academic enrichment opportunities and supportive services to help the students meet state and local standards in core content areas. The District evidences student participation by reporting attendance to the CDE. The daily attendance shall be recorded for all the students attending the after-school program on each school day the program operates. Condition There was a material weakness in internal control over compliance and noncompliance because attendance reported to the CDE was incorrect. Questioned Costs Not applicable. Context The District operates a 21 Century Program at over 60 schools. We selected a sample of five schools, and the condition applies to one of the sampled schools. For that school, the District's monthly records support 27,595 days of attendance, inclusive of ASES; however, the amount reported was 22,944, which is a difference of 4,651 or 17 percent. Cause After the District reported the attendance number to CDE, lead agencies could modify attendance records without notifying the District. Identification as a Repeat Finding See finding 2020-010 Recommendation Any changes to attendance records after the cut-off period should require manual override by responsible District officials. Views of Responsible Officials/Corrective Action Plan The State and Federal Compliance Department will develop procedures to ensure compliance with federal grants. These trainings will include the appropriate method to report, retain, and validate attendance timely.

CriteriaThe Uniform Guidance 2 CFR section 200.430 specifies the standards for documenting salaries and wages charged to federal programs. 2 CFR section 200.200 specifies the standards for documenting that direct charges to federal awards are for allowable costs.ConditionThe District did not provide sufficient documentation for us to conclude that it has implemented effective internal controls over federal compliance, as required by the Uniform Guidance.Questioned CostsKnown and likely questioned costs by program are as follows: See Schedule of Findings and Questioned Costs for chart/tableContextThe Uniform Guidance specifies documentation standards when charging activities and costs to federal grants. The District was unable to provide supporting documentation for certain expenditures. The following table shows the number of deviations in relation to the audit sample per program: See Schedule of Findings and Questioned Costs for chart/tableEffect The District is unable to provide support that all costs charged to a given program are supported, and consequently, allowable.CauseThe District is continuing to work towards full implementation of its policies and procedures surrounding federal compliance. The District?s revised time and effort documentation policies became effective during the fiscal year end June 30, 2020.Identification as a Repeat FindingSee finding 2019-008.RecommendationWe recommend management of the District to continue implementation of its newly developed policies about time and effort documentation.Views of responsible Officials/Corrective Action PlanAs of January 2021, the District has initiated proper procedures to ensure that allocations to Federal Programs are managed compliantly. There are several areas to this work to include programmatic and compliance work and training led by the Strategic Resource & Planning department in conjunction with Business Services improving the infrastructure of the financial management of the District. This places the District in a prime position to alleviate repeat findings.

CriteriaSections 200.318 through 200.326 of the Uniform Guidance specifies the procurement requirements applicable to Federal grants.ConditionMaterial weakness in internal control over compliance and noncompliance because the District could not provide evidence that vendors were selected pursuant to the criteria specified above.Questioned CostsWe were not provided sufficient documentation to calculate questioned costs.ContextThe amount charged to grants of which the Federal procurement requirements apply is $7.2 million during the current year. We selected three procurements for testing and the condition applies to two.CauseThere is no specific person accountable to ensure compliance with this requirement.Identification as a Repeat FindingThis was not identified as a 2019 compliance finding.RecommendationWe recommend that personnel responsible for Federal compliance review contracts funded by Federal grants to verify that procurements were selected per the Uniform Guidance.Views of Responsible Officials/Corrective Action PlanThe District is revamping its procedures that are currently decentralized and independent from one site/department to another. This places the District at risk for triggering compliance errors that range from the method of vendor review to the selection based on qualifications and exceeding bid thresholds. The District also has a significant missed opportunity to participate in cooperative purchasing contracts and or piggyback contracts as applicable.The District has re-assigned this critical area of focus in the assignment of the Director of Transportation and Purchasing, under the direction of the Chief Business Officer to providing the proper training and provide and secure subject matter expertise to ensure compliance and mitigate these findings.

CriteriaThe District is reimbursed for meals served to students eligible for free or reduced pricing. The reimbursement rates depend on how the student is classified. (7 CFR sections 245.2, 245.3, and 245.6; section 9(b)(1) of the NSLA (42 USC 1758 (b)(1)); sections 3(a)(6) and 4(e) of the CNA (42 USC 1772(a)(6) and 1773(e))).A child?s eligibility for free or reduced price meals under a Child Nutrition Cluster program may be established by the submission of an annual application. Children belonging to households meeting income eligibility requirements may receive meals at no charge or at reduced price. Children who have been determined ineligible for free or reduced price school meals pay the full price, set by the District, for their meals. (7 CFR sections 225.15(f), 245.1(a), and 245.3(c); definition of ?subsidized lunch (paid lunch)? at 7 CFR section 210.2).ConditionMaterial weakness in internal control over compliance and noncompliance because students are classified as eligible for free or reduced price meals, although the District did not provide a supporting application in all instances.Questioned CostsQuestioned costs associated with this condition are $628, which is an estimate of excess reimbursement received by the District that is associated with the unsupported audit samples. Likely questioned costs are $270 thousand.ContextWe selected a sample of 60 and this condition applies to two. In one case the District classified a student as eligible for reduced-price meals. The other student was classified as eligible for free meals. In both cases, the students should have been classified as ?paid? because the District did not provide the applications to support the audit.CauseThe District did not have adequate processes to review all income verification forms to ensure they meet the income eligibility requirements and retain them to support an audit.Identification as a Repeat FindingThis was not identified as a 2019 compliance finding. RecommendationPersonnel responsible for compliance in this area should ensure that all income eligibility forms are reviewed and that records are updated timely based on the review.Views of Responsible Officials/Corrective Action PlanThe Technology Staff will work closely with the Child Nutrition department to ensure complete documentation is in place and periodic review and reconciliation are completed for CALPADS certification.

CriteriaThe California Department of Education (CDE) administers California's 21st Century Community Learning Centers CCLC) program. Education Code sections 8484.7 - 8484.9 further define California's 21st CCLC Program. This state-administered, federally funded program provides five-year grant funding to establish or expand before and after school programs that provide disadvantaged kindergarten through twelfth-grade students with academic enrichment opportunities and supportive services to help the students meet state and local standards in core content areas.The District evidences student participation by reporting attendance to the CDE. The daily attendance shall be recorded for all the students attending the after school program on each school day the program operates.ConditionSignificant deficiency in internal control over compliance because attendance reported to the CDE was overstated by insignificant amounts.Questioned CostsNot applicable.ContextThe District operates a 21 Century Program at over 60 schools. We selected a sample of five schools, and the condition applies to two of the sampled schools. For one school, the District?s monthly records support 11,483 days of attendance, however the amount reported was 11,898, which is a difference of 415 or four percent. For the other school, the District?s monthly records support 27,087 days of attendance, however the amount reported was 27,370, which is a difference of 283 or one percent.CauseAfter the District reported the attendance number to CDE, lead agencies were able to enter new attendance without notifying the District.Identification as a Repeat FindingThis was not identified as a 2019 compliance finding.RecommendationAny changes to attendance records after the cut-off period should require manual override by responsible District officials.Views of Responsible Officials/Corrective Action PlanThe State and Federal Compliance Department will develop procedures to ensure compliance with federal grants. These trainings will include the appropriate method to report, retain, and validate attendance timely.

CriteriaAn LEA can use not more than 15 percent of the amount of federal Special Education Part B funds the LEA receives for any fiscal year, in combination with other funds, to develop and implement, early intervening services for children in kindergarten through grade 12 who have not been identified under IDEA but need additional academic and behavioral support to succeed in the general education environment (20 USC 1413(f); 34 CFR section 300.226).ConditionMaterial weakness in internal control and noncompliance because the District did not separately track expenditures for early intervention services from other federal special education expenditures.Questioned CostsNot applicable.Context15 percent of the fiscal year 2019-20 federal special education expenditures are $1.4 million. The District did not separately track expenditures for early intervention services.CauseThe District was unaware of the requirement to separately track expenditures for early intervention services. Identification as a Repeat FindingThis was not identified as a 2019 compliance finding.RecommendationThe District should separately track expenditures for early intervention services from other special education services so that it may demonstrate compliance.Views of Responsible Officials/Corrective Action PlanThe District did not separately track the IDEA Part B Funds in 2019-20 but has created the appropriate resources and set them aside in 2020-21.

Criteria The Uniform Guidance 2 CFR section 200.430 specifies the standards for documenting salaries and wages charged to federal programs, and 2 CFR section 200.200 specifies the standards for documenting that direct charges to Federal awards are for allowable costs. Employees who work solely on a single federal award or cost objective need only complete a periodic certification meeting certain requirements. Employees who work on multiple activities or cost objectives of which at least one is federal must complete a personnel activity report or equivalent documentation. Among others, the requirements include that activity reports must reflect an after the fact distribution of the actual activity of each employee. Activity reports must account for the total activity for which each employee is compensated. Condition Material weakness in internal control over compliance and noncompliance. During our examination of employee time and effort documentation, it was noted that management of the District was not preparing time and effort documentation meeting the aforementioned requirements. It was also noted that the District could not produce source documentation for all direct charges to federal grants. Questioned Costs Known questioned costs are $407,288 and likely (projected) questioned costs are $5,576,629. Context The total payroll charged to federal resources was $33.6 million. We randomly selected a sample of 60 transactions for time and effort documentation. Management ultimately provided us with the correct documentation for every audit sample, but the extended time delays and the fact that documentation was not prepared contemptuously is evidence of this audit finding. Total nonpayroll direct charges to federal resources were $21 million. We randomly selected a sample of 60 transactions. Management ultimately provided us with the correct documentation for every audit sample, but the extended time delays and the fact that documentation was not prepared contemptuously is evidence of this audit finding. The accounting records are detailed and provide descriptions of direct charges to federal grants. This finding is related to the District being unable to produce documents required by the uniform guidance. In such instances, we performed additional audit procedures that primarily consisted of review of alternative documents, to satisfy ourselves that the employees are engaged in an eligible activity and that direct vendor charges are otherwise permissible for the program. Effect The District is required to maintain source documentation in a form that is retrievable to support the audit. Failure to do so could result in disallowance of expenditures allocated to federal programs, even if the District otherwise complied with the underlying grant requirements. Cause The District does not have a process that facilitates the collection of these documents. There are no formal procedures, and it seems each school is tasked with the individual responsibility of compliance. The issue is compounded by the turnover of staff responsible for compliance in this area. Identification as a Repeat Finding See finding 2018-008. Recommendation The responsibility to comply with federal time accounting documents should be handled by centralized personnel at the District office. One person should be tasked with this responsibility and held accountable for compliance. The District implemented a new ERP system during the year. We recommend the District achieve all source documents in the accounting system, and designate a specific person responsible for providing the information to support the audit. Views of Responsible Officials/Corrective Action Plan Central office staff are developing procedures to address this finding. To that end, finance staff will work in cooperation with state and federal compliance staff to develop processes to ensure that documentation is available to support the audit and in compliance with grant requirements.

Criteria Title I, Part A of the Elementary and Secondary Education Act (ESEA) provides federal financial assistance to local educational agencies (LEAs) to provide supplemental services to meet the educational needs of educationally disadvantaged children. The legislation requires LEAs to provide state and local resources in Title I schools that are comparable to the services provided in non-Title I schools. This requirement continues under the Every Student Succeeds Act. (Section 1120A(c) of ESEA (20 USC 6321(c))). Condition Significant deficiency in internal control over compliance and noncompliance. Six of the District?s 71 schools did not meet the Title I comparability test because the student to staff ratio exceeded 110 percent of the average student to staff ratio of all Title I schools in the grade span. The District correctly calculated the student to staff ratio using the CDE comparability calculator. However, no action was taken to increase staffing or adjust student enrollment to achieve comparability. Questioned Costs No questioned costs are associated with this finding. Context The student-to-instructional staff ratio is not complying with the comparability requirements. Six schools out of the 71 schools that received Title I have a higher student-to-staff ratio compare to the average ratio. Cause There is no specific person accountable to ensure compliance with this requirement. The administrative staff completed the calculation, but nobody initiated action to correct the noncompliance. Identification as a Repeat Finding See finding 2018-009. Recommendation Administrative staff assigned responsibility for completing the CDE comparability calculation are not able to ensure actual compliance. After completing the calculation, there should be a single person responsible for reviewing the calculation and initiating follow-up action as necessary. Views of Responsible Officials/Corrective Action Plan The State and Federal Compliance Department will develop procedures to ensure compliance with federal grants.

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION