Newman-Crows Landing Unified School DistrictLocal Government

2025-002 Finding – Federal Funding Accountability and Transparency Act (FFATA) / Transparency Act Reporting (Timeliness) Federal Agency: U.S. Department of Health and Human Services (HHS) Program: Head Start Cluster — Assistance Listing 93.600 (Head Start) Compliance Requirement: Reporting (L) — FFATA / Transparency Act Special Reporting Type of Finding: Compliance (no internal control deficiency) Criteria Under the Transparency Act award term (2 CFR Part 170 Appendix A), recipients must report each first-tier subaward action subject to FFATA in SAM.gov no later than the end of the month following the month in which the subaward obligation was made. Condition During testing of FFATA special reporting under Reporting (L), we noted two first-tier subaward actions that were submitted in SAM.gov after the required reporting timeframe (subaward dates 9/11/2024 and 1/9/2025; SAM.gov submission date 4/16/2025). Based on the nature of the exceptions and the results of expanded procedures, the late submissions appear to be isolated to the period of the federal FSRS-to-SAM.gov transition rather than indicative of a systemic reporting breakdown. Management attributed the delays to federal system conversion issues, including access/role challenges, delayed training, and data migration/report rejection issues that required resolution with SAM.gov support. Accordingly, the noncompliance is limited to timeliness of transparency reporting (no questioned costs) and does not affect allowability of Head Start expenditures. Effect / Potential Effect Late FFATA reporting reduces the timeliness of public transparency and federal oversight information available in SAM.gov/USAspending and may increase the risk of noncompliance with federal reporting requirements; however, the matters noted did not result in questioned costs and did not affect allowability of program expenditures. Cause Management explained that the late submissions were primarily due to the federal FSRS→SAM.gov transition, including delayed federal training (Jan/Feb 2025), difficulties obtaining system access/roles, preloaded data errors in SAM.gov causing report rejections, backlogs in SAM.gov support, and staff turnover, which collectively delayed timely submission. Recommendation We recommend that SCOE continue its current FFATA reporting practices, including timely identification of first‑tier subawards subject to FFATA and submission of required data in SAM.gov, and continue maintaining documentation of reporting efforts (e.g., submission confirmations, rejection notices, and support ticket correspondence) when federal system changes or external access/data issues occur. Based on management’s explanation and the nature of the federal FSRS‑to‑SAM.gov transition challenges encountered during the period, SCOE’s response efforts (including follow‑up with SAM.gov support and corrective resubmissions as needed) appear appropriate; accordingly, no additional process changes are recommended beyond continuing the established procedures and retention of supporting evidence to demonstrate compliance in periods of federal system disruption. Questioned Costs None. Repeat Finding No. Views of Responsible Officials We acknowledge the instances of late FFATA first‑tier subaward reporting identified by the auditors. We believe the delays were primarily attributable to the federal transition from FSRS to SAM.gov, including access/role configuration challenges and system-related issues encountered during the conversion period. We took reasonable and timely steps to submit the required FFATA reports as soon as the federal system issues were resolved and to address any submission rejections or support requests as needed. We consider this condition isolated to the federal system transition period and not indicative of a systemic breakdown in our reporting processes. We intend to continue our existing FFATA reporting procedures and will continue to retain appropriate documentation of submissions and related system communications to support compliance during future federal reporting system changes.

2025-002 Finding – Federal Funding Accountability and Transparency Act (FFATA) / Transparency Act Reporting (Timeliness) Federal Agency: U.S. Department of Health and Human Services (HHS) Program: Head Start Cluster — Assistance Listing 93.600 (Head Start) Compliance Requirement: Reporting (L) — FFATA / Transparency Act Special Reporting Type of Finding: Compliance (no internal control deficiency) Criteria Under the Transparency Act award term (2 CFR Part 170 Appendix A), recipients must report each first-tier subaward action subject to FFATA in SAM.gov no later than the end of the month following the month in which the subaward obligation was made. Condition During testing of FFATA special reporting under Reporting (L), we noted two first-tier subaward actions that were submitted in SAM.gov after the required reporting timeframe (subaward dates 9/11/2024 and 1/9/2025; SAM.gov submission date 4/16/2025). Based on the nature of the exceptions and the results of expanded procedures, the late submissions appear to be isolated to the period of the federal FSRS-to-SAM.gov transition rather than indicative of a systemic reporting breakdown. Management attributed the delays to federal system conversion issues, including access/role challenges, delayed training, and data migration/report rejection issues that required resolution with SAM.gov support. Accordingly, the noncompliance is limited to timeliness of transparency reporting (no questioned costs) and does not affect allowability of Head Start expenditures. Effect / Potential Effect Late FFATA reporting reduces the timeliness of public transparency and federal oversight information available in SAM.gov/USAspending and may increase the risk of noncompliance with federal reporting requirements; however, the matters noted did not result in questioned costs and did not affect allowability of program expenditures. Cause Management explained that the late submissions were primarily due to the federal FSRS→SAM.gov transition, including delayed federal training (Jan/Feb 2025), difficulties obtaining system access/roles, preloaded data errors in SAM.gov causing report rejections, backlogs in SAM.gov support, and staff turnover, which collectively delayed timely submission. Recommendation We recommend that SCOE continue its current FFATA reporting practices, including timely identification of first‑tier subawards subject to FFATA and submission of required data in SAM.gov, and continue maintaining documentation of reporting efforts (e.g., submission confirmations, rejection notices, and support ticket correspondence) when federal system changes or external access/data issues occur. Based on management’s explanation and the nature of the federal FSRS‑to‑SAM.gov transition challenges encountered during the period, SCOE’s response efforts (including follow‑up with SAM.gov support and corrective resubmissions as needed) appear appropriate; accordingly, no additional process changes are recommended beyond continuing the established procedures and retention of supporting evidence to demonstrate compliance in periods of federal system disruption. Questioned Costs None. Repeat Finding No. Views of Responsible Officials We acknowledge the instances of late FFATA first‑tier subaward reporting identified by the auditors. We believe the delays were primarily attributable to the federal transition from FSRS to SAM.gov, including access/role configuration challenges and system-related issues encountered during the conversion period. We took reasonable and timely steps to submit the required FFATA reports as soon as the federal system issues were resolved and to address any submission rejections or support requests as needed. We consider this condition isolated to the federal system transition period and not indicative of a systemic breakdown in our reporting processes. We intend to continue our existing FFATA reporting procedures and will continue to retain appropriate documentation of submissions and related system communications to support compliance during future federal reporting system changes.

2025-002 Finding – Federal Funding Accountability and Transparency Act (FFATA) / Transparency Act Reporting (Timeliness) Federal Agency: U.S. Department of Health and Human Services (HHS) Program: Head Start Cluster — Assistance Listing 93.600 (Head Start) Compliance Requirement: Reporting (L) — FFATA / Transparency Act Special Reporting Type of Finding: Compliance (no internal control deficiency) Criteria Under the Transparency Act award term (2 CFR Part 170 Appendix A), recipients must report each first-tier subaward action subject to FFATA in SAM.gov no later than the end of the month following the month in which the subaward obligation was made. Condition During testing of FFATA special reporting under Reporting (L), we noted two first-tier subaward actions that were submitted in SAM.gov after the required reporting timeframe (subaward dates 9/11/2024 and 1/9/2025; SAM.gov submission date 4/16/2025). Based on the nature of the exceptions and the results of expanded procedures, the late submissions appear to be isolated to the period of the federal FSRS-to-SAM.gov transition rather than indicative of a systemic reporting breakdown. Management attributed the delays to federal system conversion issues, including access/role challenges, delayed training, and data migration/report rejection issues that required resolution with SAM.gov support. Accordingly, the noncompliance is limited to timeliness of transparency reporting (no questioned costs) and does not affect allowability of Head Start expenditures. Effect / Potential Effect Late FFATA reporting reduces the timeliness of public transparency and federal oversight information available in SAM.gov/USAspending and may increase the risk of noncompliance with federal reporting requirements; however, the matters noted did not result in questioned costs and did not affect allowability of program expenditures. Cause Management explained that the late submissions were primarily due to the federal FSRS→SAM.gov transition, including delayed federal training (Jan/Feb 2025), difficulties obtaining system access/roles, preloaded data errors in SAM.gov causing report rejections, backlogs in SAM.gov support, and staff turnover, which collectively delayed timely submission. Recommendation We recommend that SCOE continue its current FFATA reporting practices, including timely identification of first‑tier subawards subject to FFATA and submission of required data in SAM.gov, and continue maintaining documentation of reporting efforts (e.g., submission confirmations, rejection notices, and support ticket correspondence) when federal system changes or external access/data issues occur. Based on management’s explanation and the nature of the federal FSRS‑to‑SAM.gov transition challenges encountered during the period, SCOE’s response efforts (including follow‑up with SAM.gov support and corrective resubmissions as needed) appear appropriate; accordingly, no additional process changes are recommended beyond continuing the established procedures and retention of supporting evidence to demonstrate compliance in periods of federal system disruption. Questioned Costs None. Repeat Finding No. Views of Responsible Officials We acknowledge the instances of late FFATA first‑tier subaward reporting identified by the auditors. We believe the delays were primarily attributable to the federal transition from FSRS to SAM.gov, including access/role configuration challenges and system-related issues encountered during the conversion period. We took reasonable and timely steps to submit the required FFATA reports as soon as the federal system issues were resolved and to address any submission rejections or support requests as needed. We consider this condition isolated to the federal system transition period and not indicative of a systemic breakdown in our reporting processes. We intend to continue our existing FFATA reporting procedures and will continue to retain appropriate documentation of submissions and related system communications to support compliance during future federal reporting system changes.

2025-002 Finding – Federal Funding Accountability and Transparency Act (FFATA) / Transparency Act Reporting (Timeliness) Federal Agency: U.S. Department of Health and Human Services (HHS) Program: Head Start Cluster — Assistance Listing 93.600 (Head Start) Compliance Requirement: Reporting (L) — FFATA / Transparency Act Special Reporting Type of Finding: Compliance (no internal control deficiency) Criteria Under the Transparency Act award term (2 CFR Part 170 Appendix A), recipients must report each first-tier subaward action subject to FFATA in SAM.gov no later than the end of the month following the month in which the subaward obligation was made. Condition During testing of FFATA special reporting under Reporting (L), we noted two first-tier subaward actions that were submitted in SAM.gov after the required reporting timeframe (subaward dates 9/11/2024 and 1/9/2025; SAM.gov submission date 4/16/2025). Based on the nature of the exceptions and the results of expanded procedures, the late submissions appear to be isolated to the period of the federal FSRS-to-SAM.gov transition rather than indicative of a systemic reporting breakdown. Management attributed the delays to federal system conversion issues, including access/role challenges, delayed training, and data migration/report rejection issues that required resolution with SAM.gov support. Accordingly, the noncompliance is limited to timeliness of transparency reporting (no questioned costs) and does not affect allowability of Head Start expenditures. Effect / Potential Effect Late FFATA reporting reduces the timeliness of public transparency and federal oversight information available in SAM.gov/USAspending and may increase the risk of noncompliance with federal reporting requirements; however, the matters noted did not result in questioned costs and did not affect allowability of program expenditures. Cause Management explained that the late submissions were primarily due to the federal FSRS→SAM.gov transition, including delayed federal training (Jan/Feb 2025), difficulties obtaining system access/roles, preloaded data errors in SAM.gov causing report rejections, backlogs in SAM.gov support, and staff turnover, which collectively delayed timely submission. Recommendation We recommend that SCOE continue its current FFATA reporting practices, including timely identification of first‑tier subawards subject to FFATA and submission of required data in SAM.gov, and continue maintaining documentation of reporting efforts (e.g., submission confirmations, rejection notices, and support ticket correspondence) when federal system changes or external access/data issues occur. Based on management’s explanation and the nature of the federal FSRS‑to‑SAM.gov transition challenges encountered during the period, SCOE’s response efforts (including follow‑up with SAM.gov support and corrective resubmissions as needed) appear appropriate; accordingly, no additional process changes are recommended beyond continuing the established procedures and retention of supporting evidence to demonstrate compliance in periods of federal system disruption. Questioned Costs None. Repeat Finding No. Views of Responsible Officials We acknowledge the instances of late FFATA first‑tier subaward reporting identified by the auditors. We believe the delays were primarily attributable to the federal transition from FSRS to SAM.gov, including access/role configuration challenges and system-related issues encountered during the conversion period. We took reasonable and timely steps to submit the required FFATA reports as soon as the federal system issues were resolved and to address any submission rejections or support requests as needed. We consider this condition isolated to the federal system transition period and not indicative of a systemic breakdown in our reporting processes. We intend to continue our existing FFATA reporting procedures and will continue to retain appropriate documentation of submissions and related system communications to support compliance during future federal reporting system changes.

2025-002 Finding – Federal Funding Accountability and Transparency Act (FFATA) / Transparency Act Reporting (Timeliness) Federal Agency: U.S. Department of Health and Human Services (HHS) Program: Head Start Cluster — Assistance Listing 93.600 (Head Start) Compliance Requirement: Reporting (L) — FFATA / Transparency Act Special Reporting Type of Finding: Compliance (no internal control deficiency) Criteria Under the Transparency Act award term (2 CFR Part 170 Appendix A), recipients must report each first-tier subaward action subject to FFATA in SAM.gov no later than the end of the month following the month in which the subaward obligation was made. Condition During testing of FFATA special reporting under Reporting (L), we noted two first-tier subaward actions that were submitted in SAM.gov after the required reporting timeframe (subaward dates 9/11/2024 and 1/9/2025; SAM.gov submission date 4/16/2025). Based on the nature of the exceptions and the results of expanded procedures, the late submissions appear to be isolated to the period of the federal FSRS-to-SAM.gov transition rather than indicative of a systemic reporting breakdown. Management attributed the delays to federal system conversion issues, including access/role challenges, delayed training, and data migration/report rejection issues that required resolution with SAM.gov support. Accordingly, the noncompliance is limited to timeliness of transparency reporting (no questioned costs) and does not affect allowability of Head Start expenditures. Effect / Potential Effect Late FFATA reporting reduces the timeliness of public transparency and federal oversight information available in SAM.gov/USAspending and may increase the risk of noncompliance with federal reporting requirements; however, the matters noted did not result in questioned costs and did not affect allowability of program expenditures. Cause Management explained that the late submissions were primarily due to the federal FSRS→SAM.gov transition, including delayed federal training (Jan/Feb 2025), difficulties obtaining system access/roles, preloaded data errors in SAM.gov causing report rejections, backlogs in SAM.gov support, and staff turnover, which collectively delayed timely submission. Recommendation We recommend that SCOE continue its current FFATA reporting practices, including timely identification of first‑tier subawards subject to FFATA and submission of required data in SAM.gov, and continue maintaining documentation of reporting efforts (e.g., submission confirmations, rejection notices, and support ticket correspondence) when federal system changes or external access/data issues occur. Based on management’s explanation and the nature of the federal FSRS‑to‑SAM.gov transition challenges encountered during the period, SCOE’s response efforts (including follow‑up with SAM.gov support and corrective resubmissions as needed) appear appropriate; accordingly, no additional process changes are recommended beyond continuing the established procedures and retention of supporting evidence to demonstrate compliance in periods of federal system disruption. Questioned Costs None. Repeat Finding No. Views of Responsible Officials We acknowledge the instances of late FFATA first‑tier subaward reporting identified by the auditors. We believe the delays were primarily attributable to the federal transition from FSRS to SAM.gov, including access/role configuration challenges and system-related issues encountered during the conversion period. We took reasonable and timely steps to submit the required FFATA reports as soon as the federal system issues were resolved and to address any submission rejections or support requests as needed. We consider this condition isolated to the federal system transition period and not indicative of a systemic breakdown in our reporting processes. We intend to continue our existing FFATA reporting procedures and will continue to retain appropriate documentation of submissions and related system communications to support compliance during future federal reporting system changes.

2025-002 Finding – Federal Funding Accountability and Transparency Act (FFATA) / Transparency Act Reporting (Timeliness) Federal Agency: U.S. Department of Health and Human Services (HHS) Program: Head Start Cluster — Assistance Listing 93.600 (Head Start) Compliance Requirement: Reporting (L) — FFATA / Transparency Act Special Reporting Type of Finding: Compliance (no internal control deficiency) Criteria Under the Transparency Act award term (2 CFR Part 170 Appendix A), recipients must report each first-tier subaward action subject to FFATA in SAM.gov no later than the end of the month following the month in which the subaward obligation was made. Condition During testing of FFATA special reporting under Reporting (L), we noted two first-tier subaward actions that were submitted in SAM.gov after the required reporting timeframe (subaward dates 9/11/2024 and 1/9/2025; SAM.gov submission date 4/16/2025). Based on the nature of the exceptions and the results of expanded procedures, the late submissions appear to be isolated to the period of the federal FSRS-to-SAM.gov transition rather than indicative of a systemic reporting breakdown. Management attributed the delays to federal system conversion issues, including access/role challenges, delayed training, and data migration/report rejection issues that required resolution with SAM.gov support. Accordingly, the noncompliance is limited to timeliness of transparency reporting (no questioned costs) and does not affect allowability of Head Start expenditures. Effect / Potential Effect Late FFATA reporting reduces the timeliness of public transparency and federal oversight information available in SAM.gov/USAspending and may increase the risk of noncompliance with federal reporting requirements; however, the matters noted did not result in questioned costs and did not affect allowability of program expenditures. Cause Management explained that the late submissions were primarily due to the federal FSRS→SAM.gov transition, including delayed federal training (Jan/Feb 2025), difficulties obtaining system access/roles, preloaded data errors in SAM.gov causing report rejections, backlogs in SAM.gov support, and staff turnover, which collectively delayed timely submission. Recommendation We recommend that SCOE continue its current FFATA reporting practices, including timely identification of first‑tier subawards subject to FFATA and submission of required data in SAM.gov, and continue maintaining documentation of reporting efforts (e.g., submission confirmations, rejection notices, and support ticket correspondence) when federal system changes or external access/data issues occur. Based on management’s explanation and the nature of the federal FSRS‑to‑SAM.gov transition challenges encountered during the period, SCOE’s response efforts (including follow‑up with SAM.gov support and corrective resubmissions as needed) appear appropriate; accordingly, no additional process changes are recommended beyond continuing the established procedures and retention of supporting evidence to demonstrate compliance in periods of federal system disruption. Questioned Costs None. Repeat Finding No. Views of Responsible Officials We acknowledge the instances of late FFATA first‑tier subaward reporting identified by the auditors. We believe the delays were primarily attributable to the federal transition from FSRS to SAM.gov, including access/role configuration challenges and system-related issues encountered during the conversion period. We took reasonable and timely steps to submit the required FFATA reports as soon as the federal system issues were resolved and to address any submission rejections or support requests as needed. We consider this condition isolated to the federal system transition period and not indicative of a systemic breakdown in our reporting processes. We intend to continue our existing FFATA reporting procedures and will continue to retain appropriate documentation of submissions and related system communications to support compliance during future federal reporting system changes.

2025-002 Finding – Federal Funding Accountability and Transparency Act (FFATA) / Transparency Act Reporting (Timeliness) Federal Agency: U.S. Department of Health and Human Services (HHS) Program: Head Start Cluster — Assistance Listing 93.600 (Head Start) Compliance Requirement: Reporting (L) — FFATA / Transparency Act Special Reporting Type of Finding: Compliance (no internal control deficiency) Criteria Under the Transparency Act award term (2 CFR Part 170 Appendix A), recipients must report each first-tier subaward action subject to FFATA in SAM.gov no later than the end of the month following the month in which the subaward obligation was made. Condition During testing of FFATA special reporting under Reporting (L), we noted two first-tier subaward actions that were submitted in SAM.gov after the required reporting timeframe (subaward dates 9/11/2024 and 1/9/2025; SAM.gov submission date 4/16/2025). Based on the nature of the exceptions and the results of expanded procedures, the late submissions appear to be isolated to the period of the federal FSRS-to-SAM.gov transition rather than indicative of a systemic reporting breakdown. Management attributed the delays to federal system conversion issues, including access/role challenges, delayed training, and data migration/report rejection issues that required resolution with SAM.gov support. Accordingly, the noncompliance is limited to timeliness of transparency reporting (no questioned costs) and does not affect allowability of Head Start expenditures. Effect / Potential Effect Late FFATA reporting reduces the timeliness of public transparency and federal oversight information available in SAM.gov/USAspending and may increase the risk of noncompliance with federal reporting requirements; however, the matters noted did not result in questioned costs and did not affect allowability of program expenditures. Cause Management explained that the late submissions were primarily due to the federal FSRS→SAM.gov transition, including delayed federal training (Jan/Feb 2025), difficulties obtaining system access/roles, preloaded data errors in SAM.gov causing report rejections, backlogs in SAM.gov support, and staff turnover, which collectively delayed timely submission. Recommendation We recommend that SCOE continue its current FFATA reporting practices, including timely identification of first‑tier subawards subject to FFATA and submission of required data in SAM.gov, and continue maintaining documentation of reporting efforts (e.g., submission confirmations, rejection notices, and support ticket correspondence) when federal system changes or external access/data issues occur. Based on management’s explanation and the nature of the federal FSRS‑to‑SAM.gov transition challenges encountered during the period, SCOE’s response efforts (including follow‑up with SAM.gov support and corrective resubmissions as needed) appear appropriate; accordingly, no additional process changes are recommended beyond continuing the established procedures and retention of supporting evidence to demonstrate compliance in periods of federal system disruption. Questioned Costs None. Repeat Finding No. Views of Responsible Officials We acknowledge the instances of late FFATA first‑tier subaward reporting identified by the auditors. We believe the delays were primarily attributable to the federal transition from FSRS to SAM.gov, including access/role configuration challenges and system-related issues encountered during the conversion period. We took reasonable and timely steps to submit the required FFATA reports as soon as the federal system issues were resolved and to address any submission rejections or support requests as needed. We consider this condition isolated to the federal system transition period and not indicative of a systemic breakdown in our reporting processes. We intend to continue our existing FFATA reporting procedures and will continue to retain appropriate documentation of submissions and related system communications to support compliance during future federal reporting system changes.

2025-002 Finding – Federal Funding Accountability and Transparency Act (FFATA) / Transparency Act Reporting (Timeliness) Federal Agency: U.S. Department of Health and Human Services (HHS) Program: Head Start Cluster — Assistance Listing 93.600 (Head Start) Compliance Requirement: Reporting (L) — FFATA / Transparency Act Special Reporting Type of Finding: Compliance (no internal control deficiency) Criteria Under the Transparency Act award term (2 CFR Part 170 Appendix A), recipients must report each first-tier subaward action subject to FFATA in SAM.gov no later than the end of the month following the month in which the subaward obligation was made. Condition During testing of FFATA special reporting under Reporting (L), we noted two first-tier subaward actions that were submitted in SAM.gov after the required reporting timeframe (subaward dates 9/11/2024 and 1/9/2025; SAM.gov submission date 4/16/2025). Based on the nature of the exceptions and the results of expanded procedures, the late submissions appear to be isolated to the period of the federal FSRS-to-SAM.gov transition rather than indicative of a systemic reporting breakdown. Management attributed the delays to federal system conversion issues, including access/role challenges, delayed training, and data migration/report rejection issues that required resolution with SAM.gov support. Accordingly, the noncompliance is limited to timeliness of transparency reporting (no questioned costs) and does not affect allowability of Head Start expenditures. Effect / Potential Effect Late FFATA reporting reduces the timeliness of public transparency and federal oversight information available in SAM.gov/USAspending and may increase the risk of noncompliance with federal reporting requirements; however, the matters noted did not result in questioned costs and did not affect allowability of program expenditures. Cause Management explained that the late submissions were primarily due to the federal FSRS→SAM.gov transition, including delayed federal training (Jan/Feb 2025), difficulties obtaining system access/roles, preloaded data errors in SAM.gov causing report rejections, backlogs in SAM.gov support, and staff turnover, which collectively delayed timely submission. Recommendation We recommend that SCOE continue its current FFATA reporting practices, including timely identification of first‑tier subawards subject to FFATA and submission of required data in SAM.gov, and continue maintaining documentation of reporting efforts (e.g., submission confirmations, rejection notices, and support ticket correspondence) when federal system changes or external access/data issues occur. Based on management’s explanation and the nature of the federal FSRS‑to‑SAM.gov transition challenges encountered during the period, SCOE’s response efforts (including follow‑up with SAM.gov support and corrective resubmissions as needed) appear appropriate; accordingly, no additional process changes are recommended beyond continuing the established procedures and retention of supporting evidence to demonstrate compliance in periods of federal system disruption. Questioned Costs None. Repeat Finding No. Views of Responsible Officials We acknowledge the instances of late FFATA first‑tier subaward reporting identified by the auditors. We believe the delays were primarily attributable to the federal transition from FSRS to SAM.gov, including access/role configuration challenges and system-related issues encountered during the conversion period. We took reasonable and timely steps to submit the required FFATA reports as soon as the federal system issues were resolved and to address any submission rejections or support requests as needed. We consider this condition isolated to the federal system transition period and not indicative of a systemic breakdown in our reporting processes. We intend to continue our existing FFATA reporting procedures and will continue to retain appropriate documentation of submissions and related system communications to support compliance during future federal reporting system changes.

2025-002 Finding – Federal Funding Accountability and Transparency Act (FFATA) / Transparency Act Reporting (Timeliness) Federal Agency: U.S. Department of Health and Human Services (HHS) Program: Head Start Cluster — Assistance Listing 93.600 (Head Start) Compliance Requirement: Reporting (L) — FFATA / Transparency Act Special Reporting Type of Finding: Compliance (no internal control deficiency) Criteria Under the Transparency Act award term (2 CFR Part 170 Appendix A), recipients must report each first-tier subaward action subject to FFATA in SAM.gov no later than the end of the month following the month in which the subaward obligation was made. Condition During testing of FFATA special reporting under Reporting (L), we noted two first-tier subaward actions that were submitted in SAM.gov after the required reporting timeframe (subaward dates 9/11/2024 and 1/9/2025; SAM.gov submission date 4/16/2025). Based on the nature of the exceptions and the results of expanded procedures, the late submissions appear to be isolated to the period of the federal FSRS-to-SAM.gov transition rather than indicative of a systemic reporting breakdown. Management attributed the delays to federal system conversion issues, including access/role challenges, delayed training, and data migration/report rejection issues that required resolution with SAM.gov support. Accordingly, the noncompliance is limited to timeliness of transparency reporting (no questioned costs) and does not affect allowability of Head Start expenditures. Effect / Potential Effect Late FFATA reporting reduces the timeliness of public transparency and federal oversight information available in SAM.gov/USAspending and may increase the risk of noncompliance with federal reporting requirements; however, the matters noted did not result in questioned costs and did not affect allowability of program expenditures. Cause Management explained that the late submissions were primarily due to the federal FSRS→SAM.gov transition, including delayed federal training (Jan/Feb 2025), difficulties obtaining system access/roles, preloaded data errors in SAM.gov causing report rejections, backlogs in SAM.gov support, and staff turnover, which collectively delayed timely submission. Recommendation We recommend that SCOE continue its current FFATA reporting practices, including timely identification of first‑tier subawards subject to FFATA and submission of required data in SAM.gov, and continue maintaining documentation of reporting efforts (e.g., submission confirmations, rejection notices, and support ticket correspondence) when federal system changes or external access/data issues occur. Based on management’s explanation and the nature of the federal FSRS‑to‑SAM.gov transition challenges encountered during the period, SCOE’s response efforts (including follow‑up with SAM.gov support and corrective resubmissions as needed) appear appropriate; accordingly, no additional process changes are recommended beyond continuing the established procedures and retention of supporting evidence to demonstrate compliance in periods of federal system disruption. Questioned Costs None. Repeat Finding No. Views of Responsible Officials We acknowledge the instances of late FFATA first‑tier subaward reporting identified by the auditors. We believe the delays were primarily attributable to the federal transition from FSRS to SAM.gov, including access/role configuration challenges and system-related issues encountered during the conversion period. We took reasonable and timely steps to submit the required FFATA reports as soon as the federal system issues were resolved and to address any submission rejections or support requests as needed. We consider this condition isolated to the federal system transition period and not indicative of a systemic breakdown in our reporting processes. We intend to continue our existing FFATA reporting procedures and will continue to retain appropriate documentation of submissions and related system communications to support compliance during future federal reporting system changes.

2025-002 Finding – Federal Funding Accountability and Transparency Act (FFATA) / Transparency Act Reporting (Timeliness) Federal Agency: U.S. Department of Health and Human Services (HHS) Program: Head Start Cluster — Assistance Listing 93.600 (Head Start) Compliance Requirement: Reporting (L) — FFATA / Transparency Act Special Reporting Type of Finding: Compliance (no internal control deficiency) Criteria Under the Transparency Act award term (2 CFR Part 170 Appendix A), recipients must report each first-tier subaward action subject to FFATA in SAM.gov no later than the end of the month following the month in which the subaward obligation was made. Condition During testing of FFATA special reporting under Reporting (L), we noted two first-tier subaward actions that were submitted in SAM.gov after the required reporting timeframe (subaward dates 9/11/2024 and 1/9/2025; SAM.gov submission date 4/16/2025). Based on the nature of the exceptions and the results of expanded procedures, the late submissions appear to be isolated to the period of the federal FSRS-to-SAM.gov transition rather than indicative of a systemic reporting breakdown. Management attributed the delays to federal system conversion issues, including access/role challenges, delayed training, and data migration/report rejection issues that required resolution with SAM.gov support. Accordingly, the noncompliance is limited to timeliness of transparency reporting (no questioned costs) and does not affect allowability of Head Start expenditures. Effect / Potential Effect Late FFATA reporting reduces the timeliness of public transparency and federal oversight information available in SAM.gov/USAspending and may increase the risk of noncompliance with federal reporting requirements; however, the matters noted did not result in questioned costs and did not affect allowability of program expenditures. Cause Management explained that the late submissions were primarily due to the federal FSRS→SAM.gov transition, including delayed federal training (Jan/Feb 2025), difficulties obtaining system access/roles, preloaded data errors in SAM.gov causing report rejections, backlogs in SAM.gov support, and staff turnover, which collectively delayed timely submission. Recommendation We recommend that SCOE continue its current FFATA reporting practices, including timely identification of first‑tier subawards subject to FFATA and submission of required data in SAM.gov, and continue maintaining documentation of reporting efforts (e.g., submission confirmations, rejection notices, and support ticket correspondence) when federal system changes or external access/data issues occur. Based on management’s explanation and the nature of the federal FSRS‑to‑SAM.gov transition challenges encountered during the period, SCOE’s response efforts (including follow‑up with SAM.gov support and corrective resubmissions as needed) appear appropriate; accordingly, no additional process changes are recommended beyond continuing the established procedures and retention of supporting evidence to demonstrate compliance in periods of federal system disruption. Questioned Costs None. Repeat Finding No. Views of Responsible Officials We acknowledge the instances of late FFATA first‑tier subaward reporting identified by the auditors. We believe the delays were primarily attributable to the federal transition from FSRS to SAM.gov, including access/role configuration challenges and system-related issues encountered during the conversion period. We took reasonable and timely steps to submit the required FFATA reports as soon as the federal system issues were resolved and to address any submission rejections or support requests as needed. We consider this condition isolated to the federal system transition period and not indicative of a systemic breakdown in our reporting processes. We intend to continue our existing FFATA reporting procedures and will continue to retain appropriate documentation of submissions and related system communications to support compliance during future federal reporting system changes.

2025-002 Finding – Federal Funding Accountability and Transparency Act (FFATA) / Transparency Act Reporting (Timeliness) Federal Agency: U.S. Department of Health and Human Services (HHS) Program: Head Start Cluster — Assistance Listing 93.600 (Head Start) Compliance Requirement: Reporting (L) — FFATA / Transparency Act Special Reporting Type of Finding: Compliance (no internal control deficiency) Criteria Under the Transparency Act award term (2 CFR Part 170 Appendix A), recipients must report each first-tier subaward action subject to FFATA in SAM.gov no later than the end of the month following the month in which the subaward obligation was made. Condition During testing of FFATA special reporting under Reporting (L), we noted two first-tier subaward actions that were submitted in SAM.gov after the required reporting timeframe (subaward dates 9/11/2024 and 1/9/2025; SAM.gov submission date 4/16/2025). Based on the nature of the exceptions and the results of expanded procedures, the late submissions appear to be isolated to the period of the federal FSRS-to-SAM.gov transition rather than indicative of a systemic reporting breakdown. Management attributed the delays to federal system conversion issues, including access/role challenges, delayed training, and data migration/report rejection issues that required resolution with SAM.gov support. Accordingly, the noncompliance is limited to timeliness of transparency reporting (no questioned costs) and does not affect allowability of Head Start expenditures. Effect / Potential Effect Late FFATA reporting reduces the timeliness of public transparency and federal oversight information available in SAM.gov/USAspending and may increase the risk of noncompliance with federal reporting requirements; however, the matters noted did not result in questioned costs and did not affect allowability of program expenditures. Cause Management explained that the late submissions were primarily due to the federal FSRS→SAM.gov transition, including delayed federal training (Jan/Feb 2025), difficulties obtaining system access/roles, preloaded data errors in SAM.gov causing report rejections, backlogs in SAM.gov support, and staff turnover, which collectively delayed timely submission. Recommendation We recommend that SCOE continue its current FFATA reporting practices, including timely identification of first‑tier subawards subject to FFATA and submission of required data in SAM.gov, and continue maintaining documentation of reporting efforts (e.g., submission confirmations, rejection notices, and support ticket correspondence) when federal system changes or external access/data issues occur. Based on management’s explanation and the nature of the federal FSRS‑to‑SAM.gov transition challenges encountered during the period, SCOE’s response efforts (including follow‑up with SAM.gov support and corrective resubmissions as needed) appear appropriate; accordingly, no additional process changes are recommended beyond continuing the established procedures and retention of supporting evidence to demonstrate compliance in periods of federal system disruption. Questioned Costs None. Repeat Finding No. Views of Responsible Officials We acknowledge the instances of late FFATA first‑tier subaward reporting identified by the auditors. We believe the delays were primarily attributable to the federal transition from FSRS to SAM.gov, including access/role configuration challenges and system-related issues encountered during the conversion period. We took reasonable and timely steps to submit the required FFATA reports as soon as the federal system issues were resolved and to address any submission rejections or support requests as needed. We consider this condition isolated to the federal system transition period and not indicative of a systemic breakdown in our reporting processes. We intend to continue our existing FFATA reporting procedures and will continue to retain appropriate documentation of submissions and related system communications to support compliance during future federal reporting system changes.

2025-002 Finding – Federal Funding Accountability and Transparency Act (FFATA) / Transparency Act Reporting (Timeliness) Federal Agency: U.S. Department of Health and Human Services (HHS) Program: Head Start Cluster — Assistance Listing 93.600 (Head Start) Compliance Requirement: Reporting (L) — FFATA / Transparency Act Special Reporting Type of Finding: Compliance (no internal control deficiency) Criteria Under the Transparency Act award term (2 CFR Part 170 Appendix A), recipients must report each first-tier subaward action subject to FFATA in SAM.gov no later than the end of the month following the month in which the subaward obligation was made. Condition During testing of FFATA special reporting under Reporting (L), we noted two first-tier subaward actions that were submitted in SAM.gov after the required reporting timeframe (subaward dates 9/11/2024 and 1/9/2025; SAM.gov submission date 4/16/2025). Based on the nature of the exceptions and the results of expanded procedures, the late submissions appear to be isolated to the period of the federal FSRS-to-SAM.gov transition rather than indicative of a systemic reporting breakdown. Management attributed the delays to federal system conversion issues, including access/role challenges, delayed training, and data migration/report rejection issues that required resolution with SAM.gov support. Accordingly, the noncompliance is limited to timeliness of transparency reporting (no questioned costs) and does not affect allowability of Head Start expenditures. Effect / Potential Effect Late FFATA reporting reduces the timeliness of public transparency and federal oversight information available in SAM.gov/USAspending and may increase the risk of noncompliance with federal reporting requirements; however, the matters noted did not result in questioned costs and did not affect allowability of program expenditures. Cause Management explained that the late submissions were primarily due to the federal FSRS→SAM.gov transition, including delayed federal training (Jan/Feb 2025), difficulties obtaining system access/roles, preloaded data errors in SAM.gov causing report rejections, backlogs in SAM.gov support, and staff turnover, which collectively delayed timely submission. Recommendation We recommend that SCOE continue its current FFATA reporting practices, including timely identification of first‑tier subawards subject to FFATA and submission of required data in SAM.gov, and continue maintaining documentation of reporting efforts (e.g., submission confirmations, rejection notices, and support ticket correspondence) when federal system changes or external access/data issues occur. Based on management’s explanation and the nature of the federal FSRS‑to‑SAM.gov transition challenges encountered during the period, SCOE’s response efforts (including follow‑up with SAM.gov support and corrective resubmissions as needed) appear appropriate; accordingly, no additional process changes are recommended beyond continuing the established procedures and retention of supporting evidence to demonstrate compliance in periods of federal system disruption. Questioned Costs None. Repeat Finding No. Views of Responsible Officials We acknowledge the instances of late FFATA first‑tier subaward reporting identified by the auditors. We believe the delays were primarily attributable to the federal transition from FSRS to SAM.gov, including access/role configuration challenges and system-related issues encountered during the conversion period. We took reasonable and timely steps to submit the required FFATA reports as soon as the federal system issues were resolved and to address any submission rejections or support requests as needed. We consider this condition isolated to the federal system transition period and not indicative of a systemic breakdown in our reporting processes. We intend to continue our existing FFATA reporting procedures and will continue to retain appropriate documentation of submissions and related system communications to support compliance during future federal reporting system changes.

Federal Program Affected Program Name: COVID‐19 ‐ Elementary and Secondary School Emergency Relief (ESSER III) Fund: Learning Loss (Resource 3214), Expanded Learning Opportunities (ELO) Grant: ESSER II State Reserve (Resource 3216), and Expanded Learning Opportunities (ELO) Grant: GEER II (Resource 3217) Assistance Listing Number: 84.425U, 84.425D, 84.425C Pass‐Through Entity: California Department of Education (CDE) Federal Agency: U.S. Department of Education Criteria The United States Department of Education has approved a delegation agreement with the California Department of Education (CDE) that authorizes the CDE to provide funding to LEAs pursuant to the American Rescue Plan of 2021 (ARP Act) to address the learning loss requirement portion of ESSER III funds. Indirect costs for the total ESSER III allocation (Resource 3213 and 3214 combined) should be charged to Resource 3213 only. In addition, indirect cost for the Expanded Learning Opportunities, ESSER II State Reserves program (Resource 3216) and the Expanded Learning Opportunities, GEER II program (Resource 3217) is not allowable. Additional information is available on the on the CDE’s ARP Act Funding web page at https://www.cde.ca.gov/fg/cr/arpact.asp#esseriiialloc. Condition During our audit, we found the District incorrectly charged $24,363 of indirect costs to Resource 3214. The District’s total indirect costs, $42,097, for Resources 3213 and 3214 combined were under the LEA approved rate of 4.96%. In addition, the District incorrectly charged $15,008 of indirect costs to Resource 3216 and $3,440 of indirect costs to Resource 3217, which do not allow indirect costs for those resources. Questioned Costs A total of $42,811 in questioned costs was identified as a result of the conditions identified above. As the total indirect costs charged to resources 3213 and 3214 were under the District’s approved rate, the likely questioned cost is deemed to be $18,448 for resources 3216 (Expanding Learning Opportunities Grant (ESSER II) and Expanding Learning Opportunities Grant (GEER II). Context The conditions were identified as a result of the auditor’s federal program testing of the District’s indirect cost charges. Effect The District is out of compliance with allowable indirect cost charge requirements of the COVID‐19 ‐ Elementary and Secondary School Emergency Relief Fund programs. Cause The condition identified above appears to be due to the District not being familiar with the varying indirect cost requirements for each of the ESF federal programs. Recommendation In the 2023‐2024 fiscal year, the District should transfer $24,363 from the District’s General Fund Resource 3213 to the District’s General Fund Resource 3214, as well as, transferring $15,008 and $3,440 from the District’s General Fund unrestricted resource to Resources 3216 and 3217. In addition, the District should review their procedures to ensure it is only charging indirect costs to those programs that allow it.

Federal Program Affected Program Name: COVID‐19 ‐ Elementary and Secondary School Emergency Relief (ESSER III) Fund: Learning Loss (Resource 3214), Expanded Learning Opportunities (ELO) Grant: ESSER II State Reserve (Resource 3216), and Expanded Learning Opportunities (ELO) Grant: GEER II (Resource 3217) Assistance Listing Number: 84.425U, 84.425D, 84.425C Pass‐Through Entity: California Department of Education (CDE) Federal Agency: U.S. Department of Education Criteria The United States Department of Education has approved a delegation agreement with the California Department of Education (CDE) that authorizes the CDE to provide funding to LEAs pursuant to the American Rescue Plan of 2021 (ARP Act) to address the learning loss requirement portion of ESSER III funds. Indirect costs for the total ESSER III allocation (Resource 3213 and 3214 combined) should be charged to Resource 3213 only. In addition, indirect cost for the Expanded Learning Opportunities, ESSER II State Reserves program (Resource 3216) and the Expanded Learning Opportunities, GEER II program (Resource 3217) is not allowable. Additional information is available on the on the CDE’s ARP Act Funding web page at https://www.cde.ca.gov/fg/cr/arpact.asp#esseriiialloc. Condition During our audit, we found the District incorrectly charged $24,363 of indirect costs to Resource 3214. The District’s total indirect costs, $42,097, for Resources 3213 and 3214 combined were under the LEA approved rate of 4.96%. In addition, the District incorrectly charged $15,008 of indirect costs to Resource 3216 and $3,440 of indirect costs to Resource 3217, which do not allow indirect costs for those resources. Questioned Costs A total of $42,811 in questioned costs was identified as a result of the conditions identified above. As the total indirect costs charged to resources 3213 and 3214 were under the District’s approved rate, the likely questioned cost is deemed to be $18,448 for resources 3216 (Expanding Learning Opportunities Grant (ESSER II) and Expanding Learning Opportunities Grant (GEER II). Context The conditions were identified as a result of the auditor’s federal program testing of the District’s indirect cost charges. Effect The District is out of compliance with allowable indirect cost charge requirements of the COVID‐19 ‐ Elementary and Secondary School Emergency Relief Fund programs. Cause The condition identified above appears to be due to the District not being familiar with the varying indirect cost requirements for each of the ESF federal programs. Recommendation In the 2023‐2024 fiscal year, the District should transfer $24,363 from the District’s General Fund Resource 3213 to the District’s General Fund Resource 3214, as well as, transferring $15,008 and $3,440 from the District’s General Fund unrestricted resource to Resources 3216 and 3217. In addition, the District should review their procedures to ensure it is only charging indirect costs to those programs that allow it.

Federal Program Affected Program Name: COVID‐19 ‐ Elementary and Secondary School Emergency Relief (ESSER III) Fund: Learning Loss (Resource 3214), Expanded Learning Opportunities (ELO) Grant: ESSER II State Reserve (Resource 3216), and Expanded Learning Opportunities (ELO) Grant: GEER II (Resource 3217) Assistance Listing Number: 84.425U, 84.425D, 84.425C Pass‐Through Entity: California Department of Education (CDE) Federal Agency: U.S. Department of Education Criteria The United States Department of Education has approved a delegation agreement with the California Department of Education (CDE) that authorizes the CDE to provide funding to LEAs pursuant to the American Rescue Plan of 2021 (ARP Act) to address the learning loss requirement portion of ESSER III funds. Indirect costs for the total ESSER III allocation (Resource 3213 and 3214 combined) should be charged to Resource 3213 only. In addition, indirect cost for the Expanded Learning Opportunities, ESSER II State Reserves program (Resource 3216) and the Expanded Learning Opportunities, GEER II program (Resource 3217) is not allowable. Additional information is available on the on the CDE’s ARP Act Funding web page at https://www.cde.ca.gov/fg/cr/arpact.asp#esseriiialloc. Condition During our audit, we found the District incorrectly charged $24,363 of indirect costs to Resource 3214. The District’s total indirect costs, $42,097, for Resources 3213 and 3214 combined were under the LEA approved rate of 4.96%. In addition, the District incorrectly charged $15,008 of indirect costs to Resource 3216 and $3,440 of indirect costs to Resource 3217, which do not allow indirect costs for those resources. Questioned Costs A total of $42,811 in questioned costs was identified as a result of the conditions identified above. As the total indirect costs charged to resources 3213 and 3214 were under the District’s approved rate, the likely questioned cost is deemed to be $18,448 for resources 3216 (Expanding Learning Opportunities Grant (ESSER II) and Expanding Learning Opportunities Grant (GEER II). Context The conditions were identified as a result of the auditor’s federal program testing of the District’s indirect cost charges. Effect The District is out of compliance with allowable indirect cost charge requirements of the COVID‐19 ‐ Elementary and Secondary School Emergency Relief Fund programs. Cause The condition identified above appears to be due to the District not being familiar with the varying indirect cost requirements for each of the ESF federal programs. Recommendation In the 2023‐2024 fiscal year, the District should transfer $24,363 from the District’s General Fund Resource 3213 to the District’s General Fund Resource 3214, as well as, transferring $15,008 and $3,440 from the District’s General Fund unrestricted resource to Resources 3216 and 3217. In addition, the District should review their procedures to ensure it is only charging indirect costs to those programs that allow it.

Federal Program Affected Program Name: COVID‐19 ‐ Elementary and Secondary School Emergency Relief (ESSER III) Fund: Learning Loss (Resource 3214), Expanded Learning Opportunities (ELO) Grant: ESSER II State Reserve (Resource 3216), and Expanded Learning Opportunities (ELO) Grant: GEER II (Resource 3217) Assistance Listing Number: 84.425U, 84.425D, 84.425C Pass‐Through Entity: California Department of Education (CDE) Federal Agency: U.S. Department of Education Criteria The United States Department of Education has approved a delegation agreement with the California Department of Education (CDE) that authorizes the CDE to provide funding to LEAs pursuant to the American Rescue Plan of 2021 (ARP Act) to address the learning loss requirement portion of ESSER III funds. Indirect costs for the total ESSER III allocation (Resource 3213 and 3214 combined) should be charged to Resource 3213 only. In addition, indirect cost for the Expanded Learning Opportunities, ESSER II State Reserves program (Resource 3216) and the Expanded Learning Opportunities, GEER II program (Resource 3217) is not allowable. Additional information is available on the on the CDE’s ARP Act Funding web page at https://www.cde.ca.gov/fg/cr/arpact.asp#esseriiialloc. Condition During our audit, we found the District incorrectly charged $24,363 of indirect costs to Resource 3214. The District’s total indirect costs, $42,097, for Resources 3213 and 3214 combined were under the LEA approved rate of 4.96%. In addition, the District incorrectly charged $15,008 of indirect costs to Resource 3216 and $3,440 of indirect costs to Resource 3217, which do not allow indirect costs for those resources. Questioned Costs A total of $42,811 in questioned costs was identified as a result of the conditions identified above. As the total indirect costs charged to resources 3213 and 3214 were under the District’s approved rate, the likely questioned cost is deemed to be $18,448 for resources 3216 (Expanding Learning Opportunities Grant (ESSER II) and Expanding Learning Opportunities Grant (GEER II). Context The conditions were identified as a result of the auditor’s federal program testing of the District’s indirect cost charges. Effect The District is out of compliance with allowable indirect cost charge requirements of the COVID‐19 ‐ Elementary and Secondary School Emergency Relief Fund programs. Cause The condition identified above appears to be due to the District not being familiar with the varying indirect cost requirements for each of the ESF federal programs. Recommendation In the 2023‐2024 fiscal year, the District should transfer $24,363 from the District’s General Fund Resource 3213 to the District’s General Fund Resource 3214, as well as, transferring $15,008 and $3,440 from the District’s General Fund unrestricted resource to Resources 3216 and 3217. In addition, the District should review their procedures to ensure it is only charging indirect costs to those programs that allow it.

Federal Program Affected Program Name: COVID‐19 ‐ Elementary and Secondary School Emergency Relief (ESSER III) Fund: Learning Loss (Resource 3214), Expanded Learning Opportunities (ELO) Grant: ESSER II State Reserve (Resource 3216), and Expanded Learning Opportunities (ELO) Grant: GEER II (Resource 3217) Assistance Listing Number: 84.425U, 84.425D, 84.425C Pass‐Through Entity: California Department of Education (CDE) Federal Agency: U.S. Department of Education Criteria The United States Department of Education has approved a delegation agreement with the California Department of Education (CDE) that authorizes the CDE to provide funding to LEAs pursuant to the American Rescue Plan of 2021 (ARP Act) to address the learning loss requirement portion of ESSER III funds. Indirect costs for the total ESSER III allocation (Resource 3213 and 3214 combined) should be charged to Resource 3213 only. In addition, indirect cost for the Expanded Learning Opportunities, ESSER II State Reserves program (Resource 3216) and the Expanded Learning Opportunities, GEER II program (Resource 3217) is not allowable. Additional information is available on the on the CDE’s ARP Act Funding web page at https://www.cde.ca.gov/fg/cr/arpact.asp#esseriiialloc. Condition During our audit, we found the District incorrectly charged $24,363 of indirect costs to Resource 3214. The District’s total indirect costs, $42,097, for Resources 3213 and 3214 combined were under the LEA approved rate of 4.96%. In addition, the District incorrectly charged $15,008 of indirect costs to Resource 3216 and $3,440 of indirect costs to Resource 3217, which do not allow indirect costs for those resources. Questioned Costs A total of $42,811 in questioned costs was identified as a result of the conditions identified above. As the total indirect costs charged to resources 3213 and 3214 were under the District’s approved rate, the likely questioned cost is deemed to be $18,448 for resources 3216 (Expanding Learning Opportunities Grant (ESSER II) and Expanding Learning Opportunities Grant (GEER II). Context The conditions were identified as a result of the auditor’s federal program testing of the District’s indirect cost charges. Effect The District is out of compliance with allowable indirect cost charge requirements of the COVID‐19 ‐ Elementary and Secondary School Emergency Relief Fund programs. Cause The condition identified above appears to be due to the District not being familiar with the varying indirect cost requirements for each of the ESF federal programs. Recommendation In the 2023‐2024 fiscal year, the District should transfer $24,363 from the District’s General Fund Resource 3213 to the District’s General Fund Resource 3214, as well as, transferring $15,008 and $3,440 from the District’s General Fund unrestricted resource to Resources 3216 and 3217. In addition, the District should review their procedures to ensure it is only charging indirect costs to those programs that allow it.

Federal Program Affected Program Name: COVID‐19 ‐ Elementary and Secondary School Emergency Relief (ESSER III) Fund: Learning Loss (Resource 3214), Expanded Learning Opportunities (ELO) Grant: ESSER II State Reserve (Resource 3216), and Expanded Learning Opportunities (ELO) Grant: GEER II (Resource 3217) Assistance Listing Number: 84.425U, 84.425D, 84.425C Pass‐Through Entity: California Department of Education (CDE) Federal Agency: U.S. Department of Education Criteria The United States Department of Education has approved a delegation agreement with the California Department of Education (CDE) that authorizes the CDE to provide funding to LEAs pursuant to the American Rescue Plan of 2021 (ARP Act) to address the learning loss requirement portion of ESSER III funds. Indirect costs for the total ESSER III allocation (Resource 3213 and 3214 combined) should be charged to Resource 3213 only. In addition, indirect cost for the Expanded Learning Opportunities, ESSER II State Reserves program (Resource 3216) and the Expanded Learning Opportunities, GEER II program (Resource 3217) is not allowable. Additional information is available on the on the CDE’s ARP Act Funding web page at https://www.cde.ca.gov/fg/cr/arpact.asp#esseriiialloc. Condition During our audit, we found the District incorrectly charged $24,363 of indirect costs to Resource 3214. The District’s total indirect costs, $42,097, for Resources 3213 and 3214 combined were under the LEA approved rate of 4.96%. In addition, the District incorrectly charged $15,008 of indirect costs to Resource 3216 and $3,440 of indirect costs to Resource 3217, which do not allow indirect costs for those resources. Questioned Costs A total of $42,811 in questioned costs was identified as a result of the conditions identified above. As the total indirect costs charged to resources 3213 and 3214 were under the District’s approved rate, the likely questioned cost is deemed to be $18,448 for resources 3216 (Expanding Learning Opportunities Grant (ESSER II) and Expanding Learning Opportunities Grant (GEER II). Context The conditions were identified as a result of the auditor’s federal program testing of the District’s indirect cost charges. Effect The District is out of compliance with allowable indirect cost charge requirements of the COVID‐19 ‐ Elementary and Secondary School Emergency Relief Fund programs. Cause The condition identified above appears to be due to the District not being familiar with the varying indirect cost requirements for each of the ESF federal programs. Recommendation In the 2023‐2024 fiscal year, the District should transfer $24,363 from the District’s General Fund Resource 3213 to the District’s General Fund Resource 3214, as well as, transferring $15,008 and $3,440 from the District’s General Fund unrestricted resource to Resources 3216 and 3217. In addition, the District should review their procedures to ensure it is only charging indirect costs to those programs that allow it.

Federal Program Affected Program Name: COVID‐19 ‐ Elementary and Secondary School Emergency Relief (ESSER III) Fund: Learning Loss (Resource 3214), Expanded Learning Opportunities (ELO) Grant: ESSER II State Reserve (Resource 3216), and Expanded Learning Opportunities (ELO) Grant: GEER II (Resource 3217) Assistance Listing Number: 84.425U, 84.425D, 84.425C Pass‐Through Entity: California Department of Education (CDE) Federal Agency: U.S. Department of Education Criteria The United States Department of Education has approved a delegation agreement with the California Department of Education (CDE) that authorizes the CDE to provide funding to LEAs pursuant to the American Rescue Plan of 2021 (ARP Act) to address the learning loss requirement portion of ESSER III funds. Indirect costs for the total ESSER III allocation (Resource 3213 and 3214 combined) should be charged to Resource 3213 only. In addition, indirect cost for the Expanded Learning Opportunities, ESSER II State Reserves program (Resource 3216) and the Expanded Learning Opportunities, GEER II program (Resource 3217) is not allowable. Additional information is available on the on the CDE’s ARP Act Funding web page at https://www.cde.ca.gov/fg/cr/arpact.asp#esseriiialloc. Condition During our audit, we found the District incorrectly charged $24,363 of indirect costs to Resource 3214. The District’s total indirect costs, $42,097, for Resources 3213 and 3214 combined were under the LEA approved rate of 4.96%. In addition, the District incorrectly charged $15,008 of indirect costs to Resource 3216 and $3,440 of indirect costs to Resource 3217, which do not allow indirect costs for those resources. Questioned Costs A total of $42,811 in questioned costs was identified as a result of the conditions identified above. As the total indirect costs charged to resources 3213 and 3214 were under the District’s approved rate, the likely questioned cost is deemed to be $18,448 for resources 3216 (Expanding Learning Opportunities Grant (ESSER II) and Expanding Learning Opportunities Grant (GEER II). Context The conditions were identified as a result of the auditor’s federal program testing of the District’s indirect cost charges. Effect The District is out of compliance with allowable indirect cost charge requirements of the COVID‐19 ‐ Elementary and Secondary School Emergency Relief Fund programs. Cause The condition identified above appears to be due to the District not being familiar with the varying indirect cost requirements for each of the ESF federal programs. Recommendation In the 2023‐2024 fiscal year, the District should transfer $24,363 from the District’s General Fund Resource 3213 to the District’s General Fund Resource 3214, as well as, transferring $15,008 and $3,440 from the District’s General Fund unrestricted resource to Resources 3216 and 3217. In addition, the District should review their procedures to ensure it is only charging indirect costs to those programs that allow it.

Federal Program Affected Program Name: COVID‐19 ‐ Elementary and Secondary School Emergency Relief (ESSER III) Fund: Learning Loss (Resource 3214), Expanded Learning Opportunities (ELO) Grant: ESSER II State Reserve (Resource 3216), and Expanded Learning Opportunities (ELO) Grant: GEER II (Resource 3217) Assistance Listing Number: 84.425U, 84.425D, 84.425C Pass‐Through Entity: California Department of Education (CDE) Federal Agency: U.S. Department of Education Criteria The United States Department of Education has approved a delegation agreement with the California Department of Education (CDE) that authorizes the CDE to provide funding to LEAs pursuant to the American Rescue Plan of 2021 (ARP Act) to address the learning loss requirement portion of ESSER III funds. Indirect costs for the total ESSER III allocation (Resource 3213 and 3214 combined) should be charged to Resource 3213 only. In addition, indirect cost for the Expanded Learning Opportunities, ESSER II State Reserves program (Resource 3216) and the Expanded Learning Opportunities, GEER II program (Resource 3217) is not allowable. Additional information is available on the on the CDE’s ARP Act Funding web page at https://www.cde.ca.gov/fg/cr/arpact.asp#esseriiialloc. Condition During our audit, we found the District incorrectly charged $24,363 of indirect costs to Resource 3214. The District’s total indirect costs, $42,097, for Resources 3213 and 3214 combined were under the LEA approved rate of 4.96%. In addition, the District incorrectly charged $15,008 of indirect costs to Resource 3216 and $3,440 of indirect costs to Resource 3217, which do not allow indirect costs for those resources. Questioned Costs A total of $42,811 in questioned costs was identified as a result of the conditions identified above. As the total indirect costs charged to resources 3213 and 3214 were under the District’s approved rate, the likely questioned cost is deemed to be $18,448 for resources 3216 (Expanding Learning Opportunities Grant (ESSER II) and Expanding Learning Opportunities Grant (GEER II). Context The conditions were identified as a result of the auditor’s federal program testing of the District’s indirect cost charges. Effect The District is out of compliance with allowable indirect cost charge requirements of the COVID‐19 ‐ Elementary and Secondary School Emergency Relief Fund programs. Cause The condition identified above appears to be due to the District not being familiar with the varying indirect cost requirements for each of the ESF federal programs. Recommendation In the 2023‐2024 fiscal year, the District should transfer $24,363 from the District’s General Fund Resource 3213 to the District’s General Fund Resource 3214, as well as, transferring $15,008 and $3,440 from the District’s General Fund unrestricted resource to Resources 3216 and 3217. In addition, the District should review their procedures to ensure it is only charging indirect costs to those programs that allow it.

Federal Program Affected Program Name: COVID‐19 ‐ Elementary and Secondary School Emergency Relief (ESSER III) Fund: Learning Loss (Resource 3214), Expanded Learning Opportunities (ELO) Grant: ESSER II State Reserve (Resource 3216), and Expanded Learning Opportunities (ELO) Grant: GEER II (Resource 3217) Assistance Listing Number: 84.425U, 84.425D, 84.425C Pass‐Through Entity: California Department of Education (CDE) Federal Agency: U.S. Department of Education Criteria The United States Department of Education has approved a delegation agreement with the California Department of Education (CDE) that authorizes the CDE to provide funding to LEAs pursuant to the American Rescue Plan of 2021 (ARP Act) to address the learning loss requirement portion of ESSER III funds. Indirect costs for the total ESSER III allocation (Resource 3213 and 3214 combined) should be charged to Resource 3213 only. In addition, indirect cost for the Expanded Learning Opportunities, ESSER II State Reserves program (Resource 3216) and the Expanded Learning Opportunities, GEER II program (Resource 3217) is not allowable. Additional information is available on the on the CDE’s ARP Act Funding web page at https://www.cde.ca.gov/fg/cr/arpact.asp#esseriiialloc. Condition During our audit, we found the District incorrectly charged $24,363 of indirect costs to Resource 3214. The District’s total indirect costs, $42,097, for Resources 3213 and 3214 combined were under the LEA approved rate of 4.96%. In addition, the District incorrectly charged $15,008 of indirect costs to Resource 3216 and $3,440 of indirect costs to Resource 3217, which do not allow indirect costs for those resources. Questioned Costs A total of $42,811 in questioned costs was identified as a result of the conditions identified above. As the total indirect costs charged to resources 3213 and 3214 were under the District’s approved rate, the likely questioned cost is deemed to be $18,448 for resources 3216 (Expanding Learning Opportunities Grant (ESSER II) and Expanding Learning Opportunities Grant (GEER II). Context The conditions were identified as a result of the auditor’s federal program testing of the District’s indirect cost charges. Effect The District is out of compliance with allowable indirect cost charge requirements of the COVID‐19 ‐ Elementary and Secondary School Emergency Relief Fund programs. Cause The condition identified above appears to be due to the District not being familiar with the varying indirect cost requirements for each of the ESF federal programs. Recommendation In the 2023‐2024 fiscal year, the District should transfer $24,363 from the District’s General Fund Resource 3213 to the District’s General Fund Resource 3214, as well as, transferring $15,008 and $3,440 from the District’s General Fund unrestricted resource to Resources 3216 and 3217. In addition, the District should review their procedures to ensure it is only charging indirect costs to those programs that allow it.

Federal Program Affected Program Name: COVID‐19 ‐ Elementary and Secondary School Emergency Relief (ESSER III) Fund: Learning Loss (Resource 3214), Expanded Learning Opportunities (ELO) Grant: ESSER II State Reserve (Resource 3216), and Expanded Learning Opportunities (ELO) Grant: GEER II (Resource 3217) Assistance Listing Number: 84.425U, 84.425D, 84.425C Pass‐Through Entity: California Department of Education (CDE) Federal Agency: U.S. Department of Education Criteria The United States Department of Education has approved a delegation agreement with the California Department of Education (CDE) that authorizes the CDE to provide funding to LEAs pursuant to the American Rescue Plan of 2021 (ARP Act) to address the learning loss requirement portion of ESSER III funds. Indirect costs for the total ESSER III allocation (Resource 3213 and 3214 combined) should be charged to Resource 3213 only. In addition, indirect cost for the Expanded Learning Opportunities, ESSER II State Reserves program (Resource 3216) and the Expanded Learning Opportunities, GEER II program (Resource 3217) is not allowable. Additional information is available on the on the CDE’s ARP Act Funding web page at https://www.cde.ca.gov/fg/cr/arpact.asp#esseriiialloc. Condition During our audit, we found the District incorrectly charged $24,363 of indirect costs to Resource 3214. The District’s total indirect costs, $42,097, for Resources 3213 and 3214 combined were under the LEA approved rate of 4.96%. In addition, the District incorrectly charged $15,008 of indirect costs to Resource 3216 and $3,440 of indirect costs to Resource 3217, which do not allow indirect costs for those resources. Questioned Costs A total of $42,811 in questioned costs was identified as a result of the conditions identified above. As the total indirect costs charged to resources 3213 and 3214 were under the District’s approved rate, the likely questioned cost is deemed to be $18,448 for resources 3216 (Expanding Learning Opportunities Grant (ESSER II) and Expanding Learning Opportunities Grant (GEER II). Context The conditions were identified as a result of the auditor’s federal program testing of the District’s indirect cost charges. Effect The District is out of compliance with allowable indirect cost charge requirements of the COVID‐19 ‐ Elementary and Secondary School Emergency Relief Fund programs. Cause The condition identified above appears to be due to the District not being familiar with the varying indirect cost requirements for each of the ESF federal programs. Recommendation In the 2023‐2024 fiscal year, the District should transfer $24,363 from the District’s General Fund Resource 3213 to the District’s General Fund Resource 3214, as well as, transferring $15,008 and $3,440 from the District’s General Fund unrestricted resource to Resources 3216 and 3217. In addition, the District should review their procedures to ensure it is only charging indirect costs to those programs that allow it.

Federal Program Affected Program Name: COVID‐19 ‐ Elementary and Secondary School Emergency Relief (ESSER III) Fund: Learning Loss (Resource 3214), Expanded Learning Opportunities (ELO) Grant: ESSER II State Reserve (Resource 3216), and Expanded Learning Opportunities (ELO) Grant: GEER II (Resource 3217) Assistance Listing Number: 84.425U, 84.425D, 84.425C Pass‐Through Entity: California Department of Education (CDE) Federal Agency: U.S. Department of Education Criteria The United States Department of Education has approved a delegation agreement with the California Department of Education (CDE) that authorizes the CDE to provide funding to LEAs pursuant to the American Rescue Plan of 2021 (ARP Act) to address the learning loss requirement portion of ESSER III funds. Indirect costs for the total ESSER III allocation (Resource 3213 and 3214 combined) should be charged to Resource 3213 only. In addition, indirect cost for the Expanded Learning Opportunities, ESSER II State Reserves program (Resource 3216) and the Expanded Learning Opportunities, GEER II program (Resource 3217) is not allowable. Additional information is available on the on the CDE’s ARP Act Funding web page at https://www.cde.ca.gov/fg/cr/arpact.asp#esseriiialloc. Condition During our audit, we found the District incorrectly charged $24,363 of indirect costs to Resource 3214. The District’s total indirect costs, $42,097, for Resources 3213 and 3214 combined were under the LEA approved rate of 4.96%. In addition, the District incorrectly charged $15,008 of indirect costs to Resource 3216 and $3,440 of indirect costs to Resource 3217, which do not allow indirect costs for those resources. Questioned Costs A total of $42,811 in questioned costs was identified as a result of the conditions identified above. As the total indirect costs charged to resources 3213 and 3214 were under the District’s approved rate, the likely questioned cost is deemed to be $18,448 for resources 3216 (Expanding Learning Opportunities Grant (ESSER II) and Expanding Learning Opportunities Grant (GEER II). Context The conditions were identified as a result of the auditor’s federal program testing of the District’s indirect cost charges. Effect The District is out of compliance with allowable indirect cost charge requirements of the COVID‐19 ‐ Elementary and Secondary School Emergency Relief Fund programs. Cause The condition identified above appears to be due to the District not being familiar with the varying indirect cost requirements for each of the ESF federal programs. Recommendation In the 2023‐2024 fiscal year, the District should transfer $24,363 from the District’s General Fund Resource 3213 to the District’s General Fund Resource 3214, as well as, transferring $15,008 and $3,440 from the District’s General Fund unrestricted resource to Resources 3216 and 3217. In addition, the District should review their procedures to ensure it is only charging indirect costs to those programs that allow it.

Federal Program Affected Program Name: COVID‐19 ‐ Elementary and Secondary School Emergency Relief (ESSER III) Fund: Learning Loss (Resource 3214), Expanded Learning Opportunities (ELO) Grant: ESSER II State Reserve (Resource 3216), and Expanded Learning Opportunities (ELO) Grant: GEER II (Resource 3217) Assistance Listing Number: 84.425U, 84.425D, 84.425C Pass‐Through Entity: California Department of Education (CDE) Federal Agency: U.S. Department of Education Criteria The United States Department of Education has approved a delegation agreement with the California Department of Education (CDE) that authorizes the CDE to provide funding to LEAs pursuant to the American Rescue Plan of 2021 (ARP Act) to address the learning loss requirement portion of ESSER III funds. Indirect costs for the total ESSER III allocation (Resource 3213 and 3214 combined) should be charged to Resource 3213 only. In addition, indirect cost for the Expanded Learning Opportunities, ESSER II State Reserves program (Resource 3216) and the Expanded Learning Opportunities, GEER II program (Resource 3217) is not allowable. Additional information is available on the on the CDE’s ARP Act Funding web page at https://www.cde.ca.gov/fg/cr/arpact.asp#esseriiialloc. Condition During our audit, we found the District incorrectly charged $24,363 of indirect costs to Resource 3214. The District’s total indirect costs, $42,097, for Resources 3213 and 3214 combined were under the LEA approved rate of 4.96%. In addition, the District incorrectly charged $15,008 of indirect costs to Resource 3216 and $3,440 of indirect costs to Resource 3217, which do not allow indirect costs for those resources. Questioned Costs A total of $42,811 in questioned costs was identified as a result of the conditions identified above. As the total indirect costs charged to resources 3213 and 3214 were under the District’s approved rate, the likely questioned cost is deemed to be $18,448 for resources 3216 (Expanding Learning Opportunities Grant (ESSER II) and Expanding Learning Opportunities Grant (GEER II). Context The conditions were identified as a result of the auditor’s federal program testing of the District’s indirect cost charges. Effect The District is out of compliance with allowable indirect cost charge requirements of the COVID‐19 ‐ Elementary and Secondary School Emergency Relief Fund programs. Cause The condition identified above appears to be due to the District not being familiar with the varying indirect cost requirements for each of the ESF federal programs. Recommendation In the 2023‐2024 fiscal year, the District should transfer $24,363 from the District’s General Fund Resource 3213 to the District’s General Fund Resource 3214, as well as, transferring $15,008 and $3,440 from the District’s General Fund unrestricted resource to Resources 3216 and 3217. In addition, the District should review their procedures to ensure it is only charging indirect costs to those programs that allow it.

Federal Program Affected Program Name: COVID‐19 ‐ Elementary and Secondary School Emergency Relief (ESSER III) Fund: Learning Loss (Resource 3214), Expanded Learning Opportunities (ELO) Grant: ESSER II State Reserve (Resource 3216), and Expanded Learning Opportunities (ELO) Grant: GEER II (Resource 3217) Assistance Listing Number: 84.425U, 84.425D, 84.425C Pass‐Through Entity: California Department of Education (CDE) Federal Agency: U.S. Department of Education Criteria The United States Department of Education has approved a delegation agreement with the California Department of Education (CDE) that authorizes the CDE to provide funding to LEAs pursuant to the American Rescue Plan of 2021 (ARP Act) to address the learning loss requirement portion of ESSER III funds. Indirect costs for the total ESSER III allocation (Resource 3213 and 3214 combined) should be charged to Resource 3213 only. In addition, indirect cost for the Expanded Learning Opportunities, ESSER II State Reserves program (Resource 3216) and the Expanded Learning Opportunities, GEER II program (Resource 3217) is not allowable. Additional information is available on the on the CDE’s ARP Act Funding web page at https://www.cde.ca.gov/fg/cr/arpact.asp#esseriiialloc. Condition During our audit, we found the District incorrectly charged $24,363 of indirect costs to Resource 3214. The District’s total indirect costs, $42,097, for Resources 3213 and 3214 combined were under the LEA approved rate of 4.96%. In addition, the District incorrectly charged $15,008 of indirect costs to Resource 3216 and $3,440 of indirect costs to Resource 3217, which do not allow indirect costs for those resources. Questioned Costs A total of $42,811 in questioned costs was identified as a result of the conditions identified above. As the total indirect costs charged to resources 3213 and 3214 were under the District’s approved rate, the likely questioned cost is deemed to be $18,448 for resources 3216 (Expanding Learning Opportunities Grant (ESSER II) and Expanding Learning Opportunities Grant (GEER II). Context The conditions were identified as a result of the auditor’s federal program testing of the District’s indirect cost charges. Effect The District is out of compliance with allowable indirect cost charge requirements of the COVID‐19 ‐ Elementary and Secondary School Emergency Relief Fund programs. Cause The condition identified above appears to be due to the District not being familiar with the varying indirect cost requirements for each of the ESF federal programs. Recommendation In the 2023‐2024 fiscal year, the District should transfer $24,363 from the District’s General Fund Resource 3213 to the District’s General Fund Resource 3214, as well as, transferring $15,008 and $3,440 from the District’s General Fund unrestricted resource to Resources 3216 and 3217. In addition, the District should review their procedures to ensure it is only charging indirect costs to those programs that allow it.

Federal Program Affected Program Name: COVID‐19 ‐ Elementary and Secondary School Emergency Relief (ESSER III) Fund: Learning Loss (Resource 3214), Expanded Learning Opportunities (ELO) Grant: ESSER II State Reserve (Resource 3216), and Expanded Learning Opportunities (ELO) Grant: GEER II (Resource 3217) Assistance Listing Number: 84.425U, 84.425D, 84.425C Pass‐Through Entity: California Department of Education (CDE) Federal Agency: U.S. Department of Education Criteria The United States Department of Education has approved a delegation agreement with the California Department of Education (CDE) that authorizes the CDE to provide funding to LEAs pursuant to the American Rescue Plan of 2021 (ARP Act) to address the learning loss requirement portion of ESSER III funds. Indirect costs for the total ESSER III allocation (Resource 3213 and 3214 combined) should be charged to Resource 3213 only. In addition, indirect cost for the Expanded Learning Opportunities, ESSER II State Reserves program (Resource 3216) and the Expanded Learning Opportunities, GEER II program (Resource 3217) is not allowable. Additional information is available on the on the CDE’s ARP Act Funding web page at https://www.cde.ca.gov/fg/cr/arpact.asp#esseriiialloc. Condition During our audit, we found the District incorrectly charged $24,363 of indirect costs to Resource 3214. The District’s total indirect costs, $42,097, for Resources 3213 and 3214 combined were under the LEA approved rate of 4.96%. In addition, the District incorrectly charged $15,008 of indirect costs to Resource 3216 and $3,440 of indirect costs to Resource 3217, which do not allow indirect costs for those resources. Questioned Costs A total of $42,811 in questioned costs was identified as a result of the conditions identified above. As the total indirect costs charged to resources 3213 and 3214 were under the District’s approved rate, the likely questioned cost is deemed to be $18,448 for resources 3216 (Expanding Learning Opportunities Grant (ESSER II) and Expanding Learning Opportunities Grant (GEER II). Context The conditions were identified as a result of the auditor’s federal program testing of the District’s indirect cost charges. Effect The District is out of compliance with allowable indirect cost charge requirements of the COVID‐19 ‐ Elementary and Secondary School Emergency Relief Fund programs. Cause The condition identified above appears to be due to the District not being familiar with the varying indirect cost requirements for each of the ESF federal programs. Recommendation In the 2023‐2024 fiscal year, the District should transfer $24,363 from the District’s General Fund Resource 3213 to the District’s General Fund Resource 3214, as well as, transferring $15,008 and $3,440 from the District’s General Fund unrestricted resource to Resources 3216 and 3217. In addition, the District should review their procedures to ensure it is only charging indirect costs to those programs that allow it.

Federal Program Affected Program Name: COVID‐19 ‐ Elementary and Secondary School Emergency Relief (ESSER III) Fund: Learning Loss (Resource 3214), Expanded Learning Opportunities (ELO) Grant: ESSER II State Reserve (Resource 3216), and Expanded Learning Opportunities (ELO) Grant: GEER II (Resource 3217) Assistance Listing Number: 84.425U, 84.425D, 84.425C Pass‐Through Entity: California Department of Education (CDE) Federal Agency: U.S. Department of Education Criteria The United States Department of Education has approved a delegation agreement with the California Department of Education (CDE) that authorizes the CDE to provide funding to LEAs pursuant to the American Rescue Plan of 2021 (ARP Act) to address the learning loss requirement portion of ESSER III funds. Indirect costs for the total ESSER III allocation (Resource 3213 and 3214 combined) should be charged to Resource 3213 only. In addition, indirect cost for the Expanded Learning Opportunities, ESSER II State Reserves program (Resource 3216) and the Expanded Learning Opportunities, GEER II program (Resource 3217) is not allowable. Additional information is available on the on the CDE’s ARP Act Funding web page at https://www.cde.ca.gov/fg/cr/arpact.asp#esseriiialloc. Condition During our audit, we found the District incorrectly charged $24,363 of indirect costs to Resource 3214. The District’s total indirect costs, $42,097, for Resources 3213 and 3214 combined were under the LEA approved rate of 4.96%. In addition, the District incorrectly charged $15,008 of indirect costs to Resource 3216 and $3,440 of indirect costs to Resource 3217, which do not allow indirect costs for those resources. Questioned Costs A total of $42,811 in questioned costs was identified as a result of the conditions identified above. As the total indirect costs charged to resources 3213 and 3214 were under the District’s approved rate, the likely questioned cost is deemed to be $18,448 for resources 3216 (Expanding Learning Opportunities Grant (ESSER II) and Expanding Learning Opportunities Grant (GEER II). Context The conditions were identified as a result of the auditor’s federal program testing of the District’s indirect cost charges. Effect The District is out of compliance with allowable indirect cost charge requirements of the COVID‐19 ‐ Elementary and Secondary School Emergency Relief Fund programs. Cause The condition identified above appears to be due to the District not being familiar with the varying indirect cost requirements for each of the ESF federal programs. Recommendation In the 2023‐2024 fiscal year, the District should transfer $24,363 from the District’s General Fund Resource 3213 to the District’s General Fund Resource 3214, as well as, transferring $15,008 and $3,440 from the District’s General Fund unrestricted resource to Resources 3216 and 3217. In addition, the District should review their procedures to ensure it is only charging indirect costs to those programs that allow it.

FINDING #2021-003: FEDERAL COMPLIANCE ? TIME REPORTING (50000) CFDA Number and Title: 84.425D - Elementary and Secondary School Emergency Relief (ESSER) Fund Federal Grantor Name: U.S. Department of Education; Passed through California Department of Education Criteria: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires an accounting for personnel time on multi-funded positions by the time spent on each program and to semi-annually certify positions charged 100% to federal programs. Standards for Documentation of Personnel Expenses Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Be incorporated into the official records of the non-Federal entity ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; ? Comply with the established accounting policies and practices of the non-Federal entity ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. ? Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded during the month of November to the Education Stabilization Fund (Resource 3210). 2/2 employees tested with salaries coded to the Education Stabilization Fund (Resource 3210) during the month of February 2021 did not have any time certifications on file for the 2020-21 year. It is required that the time certifications for single funded employees be prepared twice a year and monthly for multifunded employees. Cause: The District has not been following its policy for proper time accounting. Effect: The District is not in compliance. Questioned Costs: Although the District was not in compliance, we did not find any questionable costs. Repeat Finding: This is not a repeat finding. Recommendation: We recommend they prepare time certification semi-annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan beginning on Page 70.

FINDING #2021-003: FEDERAL COMPLIANCE ? TIME REPORTING (50000) CFDA Number and Title: 84.425D - Elementary and Secondary School Emergency Relief (ESSER) Fund Federal Grantor Name: U.S. Department of Education; Passed through California Department of Education Criteria: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires an accounting for personnel time on multi-funded positions by the time spent on each program and to semi-annually certify positions charged 100% to federal programs. Standards for Documentation of Personnel Expenses Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Be incorporated into the official records of the non-Federal entity ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; ? Comply with the established accounting policies and practices of the non-Federal entity ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. ? Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded during the month of November to the Education Stabilization Fund (Resource 3210). 2/2 employees tested with salaries coded to the Education Stabilization Fund (Resource 3210) during the month of February 2021 did not have any time certifications on file for the 2020-21 year. It is required that the time certifications for single funded employees be prepared twice a year and monthly for multifunded employees. Cause: The District has not been following its policy for proper time accounting. Effect: The District is not in compliance. Questioned Costs: Although the District was not in compliance, we did not find any questionable costs. Repeat Finding: This is not a repeat finding. Recommendation: We recommend they prepare time certification semi-annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan beginning on Page 70.

FINDING #2021-003: FEDERAL COMPLIANCE ? TIME REPORTING (50000) CFDA Number and Title: 84.425D - Elementary and Secondary School Emergency Relief (ESSER) Fund Federal Grantor Name: U.S. Department of Education; Passed through California Department of Education Criteria: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires an accounting for personnel time on multi-funded positions by the time spent on each program and to semi-annually certify positions charged 100% to federal programs. Standards for Documentation of Personnel Expenses Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Be incorporated into the official records of the non-Federal entity ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; ? Comply with the established accounting policies and practices of the non-Federal entity ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. ? Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded during the month of November to the Education Stabilization Fund (Resource 3210). 2/2 employees tested with salaries coded to the Education Stabilization Fund (Resource 3210) during the month of February 2021 did not have any time certifications on file for the 2020-21 year. It is required that the time certifications for single funded employees be prepared twice a year and monthly for multifunded employees. Cause: The District has not been following its policy for proper time accounting. Effect: The District is not in compliance. Questioned Costs: Although the District was not in compliance, we did not find any questionable costs. Repeat Finding: This is not a repeat finding. Recommendation: We recommend they prepare time certification semi-annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan beginning on Page 70.

FINDING #2021-003: FEDERAL COMPLIANCE ? TIME REPORTING (50000) CFDA Number and Title: 84.425D - Elementary and Secondary School Emergency Relief (ESSER) Fund Federal Grantor Name: U.S. Department of Education; Passed through California Department of Education Criteria: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires an accounting for personnel time on multi-funded positions by the time spent on each program and to semi-annually certify positions charged 100% to federal programs. Standards for Documentation of Personnel Expenses Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Be incorporated into the official records of the non-Federal entity ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; ? Comply with the established accounting policies and practices of the non-Federal entity ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. ? Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded during the month of November to the Education Stabilization Fund (Resource 3210). 2/2 employees tested with salaries coded to the Education Stabilization Fund (Resource 3210) during the month of February 2021 did not have any time certifications on file for the 2020-21 year. It is required that the time certifications for single funded employees be prepared twice a year and monthly for multifunded employees. Cause: The District has not been following its policy for proper time accounting. Effect: The District is not in compliance. Questioned Costs: Although the District was not in compliance, we did not find any questionable costs. Repeat Finding: This is not a repeat finding. Recommendation: We recommend they prepare time certification semi-annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan beginning on Page 70.

FINDING #2021-003: FEDERAL COMPLIANCE ? TIME REPORTING (50000) CFDA Number and Title: 84.425D - Elementary and Secondary School Emergency Relief (ESSER) Fund Federal Grantor Name: U.S. Department of Education; Passed through California Department of Education Criteria: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires an accounting for personnel time on multi-funded positions by the time spent on each program and to semi-annually certify positions charged 100% to federal programs. Standards for Documentation of Personnel Expenses Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Be incorporated into the official records of the non-Federal entity ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; ? Comply with the established accounting policies and practices of the non-Federal entity ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. ? Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded during the month of November to the Education Stabilization Fund (Resource 3210). 2/2 employees tested with salaries coded to the Education Stabilization Fund (Resource 3210) during the month of February 2021 did not have any time certifications on file for the 2020-21 year. It is required that the time certifications for single funded employees be prepared twice a year and monthly for multifunded employees. Cause: The District has not been following its policy for proper time accounting. Effect: The District is not in compliance. Questioned Costs: Although the District was not in compliance, we did not find any questionable costs. Repeat Finding: This is not a repeat finding. Recommendation: We recommend they prepare time certification semi-annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan beginning on Page 70.

FINDING #2021-003: FEDERAL COMPLIANCE ? TIME REPORTING (50000) CFDA Number and Title: 84.425D - Elementary and Secondary School Emergency Relief (ESSER) Fund Federal Grantor Name: U.S. Department of Education; Passed through California Department of Education Criteria: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires an accounting for personnel time on multi-funded positions by the time spent on each program and to semi-annually certify positions charged 100% to federal programs. Standards for Documentation of Personnel Expenses Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Be incorporated into the official records of the non-Federal entity ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; ? Comply with the established accounting policies and practices of the non-Federal entity ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. ? Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded during the month of November to the Education Stabilization Fund (Resource 3210). 2/2 employees tested with salaries coded to the Education Stabilization Fund (Resource 3210) during the month of February 2021 did not have any time certifications on file for the 2020-21 year. It is required that the time certifications for single funded employees be prepared twice a year and monthly for multifunded employees. Cause: The District has not been following its policy for proper time accounting. Effect: The District is not in compliance. Questioned Costs: Although the District was not in compliance, we did not find any questionable costs. Repeat Finding: This is not a repeat finding. Recommendation: We recommend they prepare time certification semi-annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan beginning on Page 70.

FINDING #2021-003: FEDERAL COMPLIANCE ? TIME REPORTING (50000) CFDA Number and Title: 84.425D - Elementary and Secondary School Emergency Relief (ESSER) Fund Federal Grantor Name: U.S. Department of Education; Passed through California Department of Education Criteria: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires an accounting for personnel time on multi-funded positions by the time spent on each program and to semi-annually certify positions charged 100% to federal programs. Standards for Documentation of Personnel Expenses Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Be incorporated into the official records of the non-Federal entity ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; ? Comply with the established accounting policies and practices of the non-Federal entity ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. ? Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded during the month of November to the Education Stabilization Fund (Resource 3210). 2/2 employees tested with salaries coded to the Education Stabilization Fund (Resource 3210) during the month of February 2021 did not have any time certifications on file for the 2020-21 year. It is required that the time certifications for single funded employees be prepared twice a year and monthly for multifunded employees. Cause: The District has not been following its policy for proper time accounting. Effect: The District is not in compliance. Questioned Costs: Although the District was not in compliance, we did not find any questionable costs. Repeat Finding: This is not a repeat finding. Recommendation: We recommend they prepare time certification semi-annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan beginning on Page 70.

FINDING #2021-003: FEDERAL COMPLIANCE ? TIME REPORTING (50000) CFDA Number and Title: 84.425D - Elementary and Secondary School Emergency Relief (ESSER) Fund Federal Grantor Name: U.S. Department of Education; Passed through California Department of Education Criteria: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires an accounting for personnel time on multi-funded positions by the time spent on each program and to semi-annually certify positions charged 100% to federal programs. Standards for Documentation of Personnel Expenses Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Be incorporated into the official records of the non-Federal entity ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; ? Comply with the established accounting policies and practices of the non-Federal entity ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. ? Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded during the month of November to the Education Stabilization Fund (Resource 3210). 2/2 employees tested with salaries coded to the Education Stabilization Fund (Resource 3210) during the month of February 2021 did not have any time certifications on file for the 2020-21 year. It is required that the time certifications for single funded employees be prepared twice a year and monthly for multifunded employees. Cause: The District has not been following its policy for proper time accounting. Effect: The District is not in compliance. Questioned Costs: Although the District was not in compliance, we did not find any questionable costs. Repeat Finding: This is not a repeat finding. Recommendation: We recommend they prepare time certification semi-annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan beginning on Page 70.

FINDING #2021-003: FEDERAL COMPLIANCE ? TIME REPORTING (50000) CFDA Number and Title: 84.425D - Elementary and Secondary School Emergency Relief (ESSER) Fund Federal Grantor Name: U.S. Department of Education; Passed through California Department of Education Criteria: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires an accounting for personnel time on multi-funded positions by the time spent on each program and to semi-annually certify positions charged 100% to federal programs. Standards for Documentation of Personnel Expenses Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Be incorporated into the official records of the non-Federal entity ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; ? Comply with the established accounting policies and practices of the non-Federal entity ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. ? Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded during the month of November to the Education Stabilization Fund (Resource 3210). 2/2 employees tested with salaries coded to the Education Stabilization Fund (Resource 3210) during the month of February 2021 did not have any time certifications on file for the 2020-21 year. It is required that the time certifications for single funded employees be prepared twice a year and monthly for multifunded employees. Cause: The District has not been following its policy for proper time accounting. Effect: The District is not in compliance. Questioned Costs: Although the District was not in compliance, we did not find any questionable costs. Repeat Finding: This is not a repeat finding. Recommendation: We recommend they prepare time certification semi-annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan beginning on Page 70.

FINDING #2021-003: FEDERAL COMPLIANCE ? TIME REPORTING (50000) CFDA Number and Title: 84.425D - Elementary and Secondary School Emergency Relief (ESSER) Fund Federal Grantor Name: U.S. Department of Education; Passed through California Department of Education Criteria: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires an accounting for personnel time on multi-funded positions by the time spent on each program and to semi-annually certify positions charged 100% to federal programs. Standards for Documentation of Personnel Expenses Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Be incorporated into the official records of the non-Federal entity ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; ? Comply with the established accounting policies and practices of the non-Federal entity ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. ? Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded during the month of November to the Education Stabilization Fund (Resource 3210). 2/2 employees tested with salaries coded to the Education Stabilization Fund (Resource 3210) during the month of February 2021 did not have any time certifications on file for the 2020-21 year. It is required that the time certifications for single funded employees be prepared twice a year and monthly for multifunded employees. Cause: The District has not been following its policy for proper time accounting. Effect: The District is not in compliance. Questioned Costs: Although the District was not in compliance, we did not find any questionable costs. Repeat Finding: This is not a repeat finding. Recommendation: We recommend they prepare time certification semi-annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan beginning on Page 70.

FINDING #2021-003: FEDERAL COMPLIANCE ? TIME REPORTING (50000) CFDA Number and Title: 84.425D - Elementary and Secondary School Emergency Relief (ESSER) Fund Federal Grantor Name: U.S. Department of Education; Passed through California Department of Education Criteria: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires an accounting for personnel time on multi-funded positions by the time spent on each program and to semi-annually certify positions charged 100% to federal programs. Standards for Documentation of Personnel Expenses Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Be incorporated into the official records of the non-Federal entity ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; ? Comply with the established accounting policies and practices of the non-Federal entity ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. ? Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded during the month of November to the Education Stabilization Fund (Resource 3210). 2/2 employees tested with salaries coded to the Education Stabilization Fund (Resource 3210) during the month of February 2021 did not have any time certifications on file for the 2020-21 year. It is required that the time certifications for single funded employees be prepared twice a year and monthly for multifunded employees. Cause: The District has not been following its policy for proper time accounting. Effect: The District is not in compliance. Questioned Costs: Although the District was not in compliance, we did not find any questionable costs. Repeat Finding: This is not a repeat finding. Recommendation: We recommend they prepare time certification semi-annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan beginning on Page 70.

FINDING #2021-003: FEDERAL COMPLIANCE ? TIME REPORTING (50000) CFDA Number and Title: 84.425D - Elementary and Secondary School Emergency Relief (ESSER) Fund Federal Grantor Name: U.S. Department of Education; Passed through California Department of Education Criteria: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires an accounting for personnel time on multi-funded positions by the time spent on each program and to semi-annually certify positions charged 100% to federal programs. Standards for Documentation of Personnel Expenses Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Be incorporated into the official records of the non-Federal entity ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; ? Comply with the established accounting policies and practices of the non-Federal entity ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. ? Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded during the month of November to the Education Stabilization Fund (Resource 3210). 2/2 employees tested with salaries coded to the Education Stabilization Fund (Resource 3210) during the month of February 2021 did not have any time certifications on file for the 2020-21 year. It is required that the time certifications for single funded employees be prepared twice a year and monthly for multifunded employees. Cause: The District has not been following its policy for proper time accounting. Effect: The District is not in compliance. Questioned Costs: Although the District was not in compliance, we did not find any questionable costs. Repeat Finding: This is not a repeat finding. Recommendation: We recommend they prepare time certification semi-annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan beginning on Page 70.

FINDING #2021-003: FEDERAL COMPLIANCE ? TIME REPORTING (50000) CFDA Number and Title: 84.425D - Elementary and Secondary School Emergency Relief (ESSER) Fund Federal Grantor Name: U.S. Department of Education; Passed through California Department of Education Criteria: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires an accounting for personnel time on multi-funded positions by the time spent on each program and to semi-annually certify positions charged 100% to federal programs. Standards for Documentation of Personnel Expenses Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Be incorporated into the official records of the non-Federal entity ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; ? Comply with the established accounting policies and practices of the non-Federal entity ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. ? Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded during the month of November to the Education Stabilization Fund (Resource 3210). 2/2 employees tested with salaries coded to the Education Stabilization Fund (Resource 3210) during the month of February 2021 did not have any time certifications on file for the 2020-21 year. It is required that the time certifications for single funded employees be prepared twice a year and monthly for multifunded employees. Cause: The District has not been following its policy for proper time accounting. Effect: The District is not in compliance. Questioned Costs: Although the District was not in compliance, we did not find any questionable costs. Repeat Finding: This is not a repeat finding. Recommendation: We recommend they prepare time certification semi-annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan beginning on Page 70.

FINDING #2021-003: FEDERAL COMPLIANCE ? TIME REPORTING (50000) CFDA Number and Title: 84.425D - Elementary and Secondary School Emergency Relief (ESSER) Fund Federal Grantor Name: U.S. Department of Education; Passed through California Department of Education Criteria: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires an accounting for personnel time on multi-funded positions by the time spent on each program and to semi-annually certify positions charged 100% to federal programs. Standards for Documentation of Personnel Expenses Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Be incorporated into the official records of the non-Federal entity ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; ? Comply with the established accounting policies and practices of the non-Federal entity ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. ? Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded during the month of November to the Education Stabilization Fund (Resource 3210). 2/2 employees tested with salaries coded to the Education Stabilization Fund (Resource 3210) during the month of February 2021 did not have any time certifications on file for the 2020-21 year. It is required that the time certifications for single funded employees be prepared twice a year and monthly for multifunded employees. Cause: The District has not been following its policy for proper time accounting. Effect: The District is not in compliance. Questioned Costs: Although the District was not in compliance, we did not find any questionable costs. Repeat Finding: This is not a repeat finding. Recommendation: We recommend they prepare time certification semi-annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan beginning on Page 70.