Windsor Unified School DistrictLocal Government

FINDING #2024-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 areaccurate, 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, notexceeding 100% of compensated activities • Encompass both federally assisted and all other activities compensated by the non‐Federal entity on anintegrated basis, but may include the use of subsidiary records as defined in the non‐Federal entity’s writtenpolicy; • 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 theemployee works on more than one Federal award; a Federal award and non‐Federal award; an indirect costactivity and a direct cost activity; two or more indirect activities which are allocated using different allocationbases; 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 assupport for charges to Federal awards but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded to the Education Stabilization Fund. Five of five employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2023-24 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

FINDING #2024-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 areaccurate, 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, notexceeding 100% of compensated activities • Encompass both federally assisted and all other activities compensated by the non‐Federal entity on anintegrated basis, but may include the use of subsidiary records as defined in the non‐Federal entity’s writtenpolicy; • 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 theemployee works on more than one Federal award; a Federal award and non‐Federal award; an indirect costactivity and a direct cost activity; two or more indirect activities which are allocated using different allocationbases; 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 assupport for charges to Federal awards but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded to the Education Stabilization Fund. Five of five employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2023-24 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

FINDING #2024-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 areaccurate, 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, notexceeding 100% of compensated activities • Encompass both federally assisted and all other activities compensated by the non‐Federal entity on anintegrated basis, but may include the use of subsidiary records as defined in the non‐Federal entity’s writtenpolicy; • 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 theemployee works on more than one Federal award; a Federal award and non‐Federal award; an indirect costactivity and a direct cost activity; two or more indirect activities which are allocated using different allocationbases; 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 assupport for charges to Federal awards but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded to the Education Stabilization Fund. Five of five employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2023-24 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

FINDING #2024-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 areaccurate, 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, notexceeding 100% of compensated activities • Encompass both federally assisted and all other activities compensated by the non‐Federal entity on anintegrated basis, but may include the use of subsidiary records as defined in the non‐Federal entity’s writtenpolicy; • 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 theemployee works on more than one Federal award; a Federal award and non‐Federal award; an indirect costactivity and a direct cost activity; two or more indirect activities which are allocated using different allocationbases; 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 assupport for charges to Federal awards but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded to the Education Stabilization Fund. Five of five employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2023-24 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

FINDING #2024-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 areaccurate, 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, notexceeding 100% of compensated activities • Encompass both federally assisted and all other activities compensated by the non‐Federal entity on anintegrated basis, but may include the use of subsidiary records as defined in the non‐Federal entity’s writtenpolicy; • 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 theemployee works on more than one Federal award; a Federal award and non‐Federal award; an indirect costactivity and a direct cost activity; two or more indirect activities which are allocated using different allocationbases; 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 assupport for charges to Federal awards but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded to the Education Stabilization Fund. Five of five employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2023-24 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

FINDING #2024-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 areaccurate, 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, notexceeding 100% of compensated activities • Encompass both federally assisted and all other activities compensated by the non‐Federal entity on anintegrated basis, but may include the use of subsidiary records as defined in the non‐Federal entity’s writtenpolicy; • 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 theemployee works on more than one Federal award; a Federal award and non‐Federal award; an indirect costactivity and a direct cost activity; two or more indirect activities which are allocated using different allocationbases; 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 assupport for charges to Federal awards but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded to the Education Stabilization Fund. Five of five employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2023-24 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

FINDING #2024-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 areaccurate, 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, notexceeding 100% of compensated activities • Encompass both federally assisted and all other activities compensated by the non‐Federal entity on anintegrated basis, but may include the use of subsidiary records as defined in the non‐Federal entity’s writtenpolicy; • 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 theemployee works on more than one Federal award; a Federal award and non‐Federal award; an indirect costactivity and a direct cost activity; two or more indirect activities which are allocated using different allocationbases; 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 assupport for charges to Federal awards but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded to the Education Stabilization Fund. Five of five employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2023-24 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

FINDING #2024-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 areaccurate, 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, notexceeding 100% of compensated activities • Encompass both federally assisted and all other activities compensated by the non‐Federal entity on anintegrated basis, but may include the use of subsidiary records as defined in the non‐Federal entity’s writtenpolicy; • 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 theemployee works on more than one Federal award; a Federal award and non‐Federal award; an indirect costactivity and a direct cost activity; two or more indirect activities which are allocated using different allocationbases; 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 assupport for charges to Federal awards but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded to the Education Stabilization Fund. Five of five employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2023-24 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

FINDING #2024-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 areaccurate, 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, notexceeding 100% of compensated activities • Encompass both federally assisted and all other activities compensated by the non‐Federal entity on anintegrated basis, but may include the use of subsidiary records as defined in the non‐Federal entity’s writtenpolicy; • 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 theemployee works on more than one Federal award; a Federal award and non‐Federal award; an indirect costactivity and a direct cost activity; two or more indirect activities which are allocated using different allocationbases; 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 assupport for charges to Federal awards but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded to the Education Stabilization Fund. Five of five employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2023-24 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

FINDING #2024-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 areaccurate, 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, notexceeding 100% of compensated activities • Encompass both federally assisted and all other activities compensated by the non‐Federal entity on anintegrated basis, but may include the use of subsidiary records as defined in the non‐Federal entity’s writtenpolicy; • 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 theemployee works on more than one Federal award; a Federal award and non‐Federal award; an indirect costactivity and a direct cost activity; two or more indirect activities which are allocated using different allocationbases; 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 assupport for charges to Federal awards but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded to the Education Stabilization Fund. Five of five employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2023-24 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

FINDING #2024-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 areaccurate, 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, notexceeding 100% of compensated activities • Encompass both federally assisted and all other activities compensated by the non‐Federal entity on anintegrated basis, but may include the use of subsidiary records as defined in the non‐Federal entity’s writtenpolicy; • 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 theemployee works on more than one Federal award; a Federal award and non‐Federal award; an indirect costactivity and a direct cost activity; two or more indirect activities which are allocated using different allocationbases; 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 assupport for charges to Federal awards but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded to the Education Stabilization Fund. Five of five employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2023-24 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

FINDING #2023-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 to the Education Stabilization Fund. Six of six employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

Auditor selected employees with salaries coded to the Education Stabilization Fund. Three of three employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded employees.

FINDING #2023-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 to the Education Stabilization Fund. Six of six employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

Auditor selected employees with salaries coded to the Education Stabilization Fund. Three of three employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded employees.

FINDING #2023-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 to the Education Stabilization Fund. Six of six employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

Auditor selected employees with salaries coded to the Education Stabilization Fund. Three of three employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded employees.

FINDING #2023-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 to the Education Stabilization Fund. Six of six employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

Auditor selected employees with salaries coded to the Education Stabilization Fund. Three of three employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded employees.

FINDING #2023-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 to the Education Stabilization Fund. Six of six employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

Auditor selected employees with salaries coded to the Education Stabilization Fund. Three of three employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded employees.

FINDING #2023-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 to the Education Stabilization Fund. Six of six employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

Auditor selected employees with salaries coded to the Education Stabilization Fund. Three of three employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded employees.

FINDING #2023-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 to the Education Stabilization Fund. Six of six employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

Auditor selected employees with salaries coded to the Education Stabilization Fund. Three of three employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded employees.

FINDING #2023-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 to the Education Stabilization Fund. Six of six employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

Auditor selected employees with salaries coded to the Education Stabilization Fund. Three of three employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded employees.

FINDING #2023-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 to the Education Stabilization Fund. Six of six employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

Auditor selected employees with salaries coded to the Education Stabilization Fund. Three of three employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded employees.

FINDING #2023-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 to the Education Stabilization Fund. Six of six employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

Auditor selected employees with salaries coded to the Education Stabilization Fund. Three of three employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded employees.

FINDING #2023-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 to the Education Stabilization Fund. Six of six employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

Auditor selected employees with salaries coded to the Education Stabilization Fund. Three of three employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded employees.

FINDING #2023-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 to the Education Stabilization Fund. Six of six employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

Auditor selected employees with salaries coded to the Education Stabilization Fund. Three of three employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded employees.

FINDING #2023-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, 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 to the Education Stabilization Fund. Six of six employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded 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 were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the District prepares time certification semi‐annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

Auditor selected employees with salaries coded to the Education Stabilization Fund. Three of three employees tested with salaries coded to the Education Stabilization Fund during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi- funded employees.

U.S. Department of Education - Passed through California Department of Education Title I Part A CFDA 84.010 2018-19 TITLE I SCHOOLWIDE PROGRAMS Criteria: Title I Schoolwide Programs (SWP) should consider the following general criteria when approving activities or expenditures supported with Title I, Part A funds: ? The activity/expenditure meets a need identified in the comprehensive needs assessment (ESSA Section 1114(b)(6); ? The activity/expenditure is included in the Single Plan for Student Achievement (SPSA) (Education Code Section 64001(g)(C)(3). ? The activity/expenditure has been reviewed, approved, and recommended by the Schoolsite Council to the local governing board (Education Code Section 64001(d). Condition: The SPSA did not include the proposed expenditure of funds, allocated to the schools through the consolidated application, to address findings identified in needs assessment. Questioned Cost: None. We determined that Title I, Part A funds were spent on student support teachers and that payroll charges allocated to the Title I, Part A program were supported by time and effort distribution records in accordance with 2 CFR 200.430(i)(1)(vii). Context: The condition was noted at Binkley Elementary and Douglas Whited Elementary charter schools. Effect: The District did not comply with Federal and State requirements related to Title I Schoolwide Programs. Cause: The District office did not review the SPSA prepared by school sites to ensure that they complied with Federal and State requirements. Recommendation: The District office should review the Federal and State guidelines for preparing and documenting activities/expenditures in the SPSA.

U.S. Department of Education - Passed through California Department of Education Title I Part A CFDA 84.010 2018-19 TITLE I SCHOOLWIDE PROGRAMS Criteria: Title I Schoolwide Programs (SWP) should consider the following general criteria when approving activities or expenditures supported with Title I, Part A funds: ? The activity/expenditure meets a need identified in the comprehensive needs assessment (ESSA Section 1114(b)(6); ? The activity/expenditure is included in the Single Plan for Student Achievement (SPSA) (Education Code Section 64001(g)(C)(3). ? The activity/expenditure has been reviewed, approved, and recommended by the Schoolsite Council to the local governing board (Education Code Section 64001(d). Condition: The SPSA did not include the proposed expenditure of funds, allocated to the schools through the consolidated application, to address findings identified in needs assessment. Questioned Cost: None. We determined that Title I, Part A funds were spent on student support teachers and that payroll charges allocated to the Title I, Part A program were supported by time and effort distribution records in accordance with 2 CFR 200.430(i)(1)(vii). Context: The condition was noted at Binkley Elementary and Douglas Whited Elementary charter schools. Effect: The District did not comply with Federal and State requirements related to Title I Schoolwide Programs. Cause: The District office did not review the SPSA prepared by school sites to ensure that they complied with Federal and State requirements. Recommendation: The District office should review the Federal and State guidelines for preparing and documenting activities/expenditures in the SPSA.

U.S. Department of Education - Passed through California Department of Education Title I Part A CFDA 84.010 2018-19 TITLE I SCHOOLWIDE PROGRAMS Criteria: Title I Schoolwide Programs (SWP) should consider the following general criteria when approving activities or expenditures supported with Title I, Part A funds: ? The activity/expenditure meets a need identified in the comprehensive needs assessment (ESSA Section 1114(b)(6); ? The activity/expenditure is included in the Single Plan for Student Achievement (SPSA) (Education Code Section 64001(g)(C)(3). ? The activity/expenditure has been reviewed, approved, and recommended by the Schoolsite Council to the local governing board (Education Code Section 64001(d). Condition: The SPSA did not include the proposed expenditure of funds, allocated to the schools through the consolidated application, to address findings identified in needs assessment. Questioned Cost: None. We determined that Title I, Part A funds were spent on student support teachers and that payroll charges allocated to the Title I, Part A program were supported by time and effort distribution records in accordance with 2 CFR 200.430(i)(1)(vii). Context: The condition was noted at Binkley Elementary and Douglas Whited Elementary charter schools. Effect: The District did not comply with Federal and State requirements related to Title I Schoolwide Programs. Cause: The District office did not review the SPSA prepared by school sites to ensure that they complied with Federal and State requirements. Recommendation: The District office should review the Federal and State guidelines for preparing and documenting activities/expenditures in the SPSA.

U.S. Department of Education - Passed through California Department of Education Title I Part A CFDA 84.010 2018-19 TITLE I SCHOOLWIDE PROGRAMS Criteria: Title I Schoolwide Programs (SWP) should consider the following general criteria when approving activities or expenditures supported with Title I, Part A funds: ? The activity/expenditure meets a need identified in the comprehensive needs assessment (ESSA Section 1114(b)(6); ? The activity/expenditure is included in the Single Plan for Student Achievement (SPSA) (Education Code Section 64001(g)(C)(3). ? The activity/expenditure has been reviewed, approved, and recommended by the Schoolsite Council to the local governing board (Education Code Section 64001(d). Condition: The SPSA did not include the proposed expenditure of funds, allocated to the schools through the consolidated application, to address findings identified in needs assessment. Questioned Cost: None. We determined that Title I, Part A funds were spent on student support teachers and that payroll charges allocated to the Title I, Part A program were supported by time and effort distribution records in accordance with 2 CFR 200.430(i)(1)(vii). Context: The condition was noted at Binkley Elementary and Douglas Whited Elementary charter schools. Effect: The District did not comply with Federal and State requirements related to Title I Schoolwide Programs. Cause: The District office did not review the SPSA prepared by school sites to ensure that they complied with Federal and State requirements. Recommendation: The District office should review the Federal and State guidelines for preparing and documenting activities/expenditures in the SPSA.

U.S. Department of Education - Passed through California Department of Education Title I Part A CFDA 84.010 2018-19 TITLE I SCHOOLWIDE PROGRAMS Criteria: Title I Schoolwide Programs (SWP) should consider the following general criteria when approving activities or expenditures supported with Title I, Part A funds: ? The activity/expenditure meets a need identified in the comprehensive needs assessment (ESSA Section 1114(b)(6); ? The activity/expenditure is included in the Single Plan for Student Achievement (SPSA) (Education Code Section 64001(g)(C)(3). ? The activity/expenditure has been reviewed, approved, and recommended by the Schoolsite Council to the local governing board (Education Code Section 64001(d). Condition: The SPSA did not include the proposed expenditure of funds, allocated to the schools through the consolidated application, to address findings identified in needs assessment. Questioned Cost: None. We determined that Title I, Part A funds were spent on student support teachers and that payroll charges allocated to the Title I, Part A program were supported by time and effort distribution records in accordance with 2 CFR 200.430(i)(1)(vii). Context: The condition was noted at Binkley Elementary and Douglas Whited Elementary charter schools. Effect: The District did not comply with Federal and State requirements related to Title I Schoolwide Programs. Cause: The District office did not review the SPSA prepared by school sites to ensure that they complied with Federal and State requirements. Recommendation: The District office should review the Federal and State guidelines for preparing and documenting activities/expenditures in the SPSA.

U.S. Department of Education - Passed through California Department of Education Title I Part A CFDA 84.010 2018-19 TITLE I SCHOOLWIDE PROGRAMS Criteria: Title I Schoolwide Programs (SWP) should consider the following general criteria when approving activities or expenditures supported with Title I, Part A funds: ? The activity/expenditure meets a need identified in the comprehensive needs assessment (ESSA Section 1114(b)(6); ? The activity/expenditure is included in the Single Plan for Student Achievement (SPSA) (Education Code Section 64001(g)(C)(3). ? The activity/expenditure has been reviewed, approved, and recommended by the Schoolsite Council to the local governing board (Education Code Section 64001(d). Condition: The SPSA did not include the proposed expenditure of funds, allocated to the schools through the consolidated application, to address findings identified in needs assessment. Questioned Cost: None. We determined that Title I, Part A funds were spent on student support teachers and that payroll charges allocated to the Title I, Part A program were supported by time and effort distribution records in accordance with 2 CFR 200.430(i)(1)(vii). Context: The condition was noted at Binkley Elementary and Douglas Whited Elementary charter schools. Effect: The District did not comply with Federal and State requirements related to Title I Schoolwide Programs. Cause: The District office did not review the SPSA prepared by school sites to ensure that they complied with Federal and State requirements. Recommendation: The District office should review the Federal and State guidelines for preparing and documenting activities/expenditures in the SPSA.

U.S. Department of Education - Passed through California Department of Education Title I Part A CFDA 84.010 2018-19 TITLE I SCHOOLWIDE PROGRAMS Criteria: Title I Schoolwide Programs (SWP) should consider the following general criteria when approving activities or expenditures supported with Title I, Part A funds: ? The activity/expenditure meets a need identified in the comprehensive needs assessment (ESSA Section 1114(b)(6); ? The activity/expenditure is included in the Single Plan for Student Achievement (SPSA) (Education Code Section 64001(g)(C)(3). ? The activity/expenditure has been reviewed, approved, and recommended by the Schoolsite Council to the local governing board (Education Code Section 64001(d). Condition: The SPSA did not include the proposed expenditure of funds, allocated to the schools through the consolidated application, to address findings identified in needs assessment. Questioned Cost: None. We determined that Title I, Part A funds were spent on student support teachers and that payroll charges allocated to the Title I, Part A program were supported by time and effort distribution records in accordance with 2 CFR 200.430(i)(1)(vii). Context: The condition was noted at Binkley Elementary and Douglas Whited Elementary charter schools. Effect: The District did not comply with Federal and State requirements related to Title I Schoolwide Programs. Cause: The District office did not review the SPSA prepared by school sites to ensure that they complied with Federal and State requirements. Recommendation: The District office should review the Federal and State guidelines for preparing and documenting activities/expenditures in the SPSA.

U.S. Department of Education - Passed through California Department of Education Title I Part A CFDA 84.010 2018-19 TITLE I SCHOOLWIDE PROGRAMS Criteria: Title I Schoolwide Programs (SWP) should consider the following general criteria when approving activities or expenditures supported with Title I, Part A funds: ? The activity/expenditure meets a need identified in the comprehensive needs assessment (ESSA Section 1114(b)(6); ? The activity/expenditure is included in the Single Plan for Student Achievement (SPSA) (Education Code Section 64001(g)(C)(3). ? The activity/expenditure has been reviewed, approved, and recommended by the Schoolsite Council to the local governing board (Education Code Section 64001(d). Condition: The SPSA did not include the proposed expenditure of funds, allocated to the schools through the consolidated application, to address findings identified in needs assessment. Questioned Cost: None. We determined that Title I, Part A funds were spent on student support teachers and that payroll charges allocated to the Title I, Part A program were supported by time and effort distribution records in accordance with 2 CFR 200.430(i)(1)(vii). Context: The condition was noted at Binkley Elementary and Douglas Whited Elementary charter schools. Effect: The District did not comply with Federal and State requirements related to Title I Schoolwide Programs. Cause: The District office did not review the SPSA prepared by school sites to ensure that they complied with Federal and State requirements. Recommendation: The District office should review the Federal and State guidelines for preparing and documenting activities/expenditures in the SPSA.

U.S. Department of Education - Passed through California Department of Education Title I Part A CFDA 84.010 2018-19 TITLE I SCHOOLWIDE PROGRAMS Criteria: Title I Schoolwide Programs (SWP) should consider the following general criteria when approving activities or expenditures supported with Title I, Part A funds: ? The activity/expenditure meets a need identified in the comprehensive needs assessment (ESSA Section 1114(b)(6); ? The activity/expenditure is included in the Single Plan for Student Achievement (SPSA) (Education Code Section 64001(g)(C)(3). ? The activity/expenditure has been reviewed, approved, and recommended by the Schoolsite Council to the local governing board (Education Code Section 64001(d). Condition: The SPSA did not include the proposed expenditure of funds, allocated to the schools through the consolidated application, to address findings identified in needs assessment. Questioned Cost: None. We determined that Title I, Part A funds were spent on student support teachers and that payroll charges allocated to the Title I, Part A program were supported by time and effort distribution records in accordance with 2 CFR 200.430(i)(1)(vii). Context: The condition was noted at Binkley Elementary and Douglas Whited Elementary charter schools. Effect: The District did not comply with Federal and State requirements related to Title I Schoolwide Programs. Cause: The District office did not review the SPSA prepared by school sites to ensure that they complied with Federal and State requirements. Recommendation: The District office should review the Federal and State guidelines for preparing and documenting activities/expenditures in the SPSA.

U.S. Department of Education - Passed through California Department of Education Title I Part A CFDA 84.010 2018-19 TITLE I SCHOOLWIDE PROGRAMS Criteria: Title I Schoolwide Programs (SWP) should consider the following general criteria when approving activities or expenditures supported with Title I, Part A funds: ? The activity/expenditure meets a need identified in the comprehensive needs assessment (ESSA Section 1114(b)(6); ? The activity/expenditure is included in the Single Plan for Student Achievement (SPSA) (Education Code Section 64001(g)(C)(3). ? The activity/expenditure has been reviewed, approved, and recommended by the Schoolsite Council to the local governing board (Education Code Section 64001(d). Condition: The SPSA did not include the proposed expenditure of funds, allocated to the schools through the consolidated application, to address findings identified in needs assessment. Questioned Cost: None. We determined that Title I, Part A funds were spent on student support teachers and that payroll charges allocated to the Title I, Part A program were supported by time and effort distribution records in accordance with 2 CFR 200.430(i)(1)(vii). Context: The condition was noted at Binkley Elementary and Douglas Whited Elementary charter schools. Effect: The District did not comply with Federal and State requirements related to Title I Schoolwide Programs. Cause: The District office did not review the SPSA prepared by school sites to ensure that they complied with Federal and State requirements. Recommendation: The District office should review the Federal and State guidelines for preparing and documenting activities/expenditures in the SPSA.

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