LAS VIRGENES UNIFIED SCHOOL DISTRICTLocal Government

Finding 2024‐001: Title I – Compliance Requirement for Cohort Graduation Rate Not Met (30000) (50000) Assistance Listing #84.010—Title I, U.S. Department of Education, California Department of Education Repeat Finding? No Criteria: 34 CFR, section 200.19(b) states, in part: High schools – (1) Graduation rate. Consistent with paragraphs (b)(4) and (b)(5) of this section regarding reporting and determining AYP, respectively, each State must calculate a graduation rate, defined as follows, for all public high schools in the State: (i) (A) A State must calculate a “four-year adjusted cohort graduation rate,” defined as the number of students who graduate in four years with a regular high school diploma divided by the number of students who form the adjusted cohort for that graduating class. (B) For those high schools that start after grade nine, the cohort must be calculated based on the earliest high school grade. (ii) The term “adjusted cohort” means the students who enter grade 9 (or the earliest high school grade) and any students who transfer into the cohort in grades 9 through 12 minus any students removed from the cohort. (A) The term “students who transfer into the cohort” means the students who enroll after the beginning of the entering cohort's first year in high school, up to and including in grade 12. (B) To remove a student from the cohort, a school or LEA must confirm in writing that the student transferred out, immigrated to another country, or is deceased. (1) To confirm that a student transferred out, the school or LEA must have official written documentation that the student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. (2) A student who is retained in grade, enrolls in a General Educational Development (GED) program, or leaves school for any other reason may not be counted as having transferred out for the purpose of calculating graduation rate and must remain in the adjusted cohort. Condition: During our review of the District’s Title I program, we noted that the District did not maintain written documentation supporting that a student has enrolled in another school or in an education program that culminates in the awarding of a regular high school diploma. The District is required to maintain official written documentation supporting that a student has enrolled in another school or in an educational program that culminates in the awarding of a regular high school diploma. A student who is retained in-grade or leaves school for any other reason may not be counted as having transferred out for the purpose of calculating graduation rates, and must remain in the adjusted cohort. Context: The CDE uses the student-level data maintained in CALPADS to calculate the four-year adjusted cohort graduation rate for all LEAs in the state. We selected eleven students who were identified in CALPADS as transfer students who withdrew from the District. The District was unable to provide any written documentation to confirm that two of these students transferred out of the District and emigrated to another county or enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. Effect/Questioned Costs: We were unable to determine whether the District implemented policies and procedures for documenting the removal of students from the regulatory adjusted cohort. There are no questioned costs as a result of this finding. Cause: The District did not maintain adequate documentation to support the removal of a student from the regulatory adjusted cohort. Recommendation: We recommend that the District implement appropriate controls necessary for documenting the removal of students from the regulatory adjusted cohort, and ensure that the supporting documentation is maintained. Views of Responsible Officials: Dr. Ryan Gleason will work with the Educational Services Department to ensure that we follow this procedure for all students moving forward. The student in question attended a residential treatment facility and was not tracked beyond that placement.

Federal Program Affected Federal Agency: U.S. Department of Education Pass-through Entity: California Department of Education Federal Program: Education Stabilization Fund (ESF) ALN: 84.425D & 84.425U (FY 2022-2023) Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency and Non-Compliance Criteria or Specific Requirements The Code of Federal Regulations, Title 2, Subtitle A, Chapter II, Part 200, Subpart E, Section 200.439(a)(1) states: “Capital expenditures for general purpose equipment, buildings, and land are unallowable as direct charges, except with the prior written approval of the Federal awarding agency or passthrough entity.” Furthermore, the California Department of Education’s (CDE) FAQs on Capital Expenditures state the following: “In accordance with 2 CFR 200.439, prior approval is required for any single big-ticket purchases at the cost of $5,000 or more using the funding sources cited above. These purchases can include general purpose equipment, buildings, and land, including material improvements. This means one costly item (or several items which make up one unit) and the cost includes all the ancillary expenses such as design costs, new electrical circuit for the item, and other related fees. To obtain approval, an LEA must fill out the Capital Expenditures Pre-Approval Application Form” Condition The District had a total of $305,312 in capital expenditures charged to ESF that was not preapproved by CDE. Questioned Costs A total of $305,312 in questioned costs were noted based on the condition identified. Context The condition was identified as a result of our review and testing of expenditures charged to various ESF programs. Effect As a result of the condition identified, the District was not in compliance with the Code of Federal Regulations, Title 2, Subtitle A, Chapter II, Part 200, Subpart E, Section 200.439(a)(1). Cause The cause appears to be attribute to the District’s improper monitoring and lack of knowledge over this specific compliance requirement. Additionally, a contributing factor appears to be a turnover in a key position that provides oversight for this program. Repeat Finding No. Recommendation The District should become familiar with all of the compliance requirements with ESF. As a resource, the District should utilize a combination of guidance provided by CDE and also by Subpart E of the Uniform Guidance that provides guidance on cost principles. Additionally, the District should establish more effective control activities and monitoring over how Federal funds are spent to ensure compliance, moving forward.

50000 (Reporting, Material Weakness) Federal Program Affected Federal Agency: U.S. Department of Health and Human Services Pass-through Entity: Los Angeles County Office of Education Federal Program: COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases CFDA/ALN: 93.323 (FY 2021-2022) Compliance Requirement: Reporting Type of Finding: Material Weakness and Material Non-Compliance Criteria or Specific Requirements Under the sub-granting conditions and grant agreements between the District and the Los Angeles County Office of Education (LACOE), the District is required to perform the following under Section 4.2.4 of the grant agreement: Submit weekly progress reports and monthly financial reports to LACOE. The reports will include the following information: ? Total enrollment ? Number of individuals tested (student and staff) ? Number of testing locations ? Number of tests ? PCR (total and positive tests) ? Number of tests ? Antigen (total and positive tests) ? Number of tests ? Other (type of test; total and positive tests) ? Total positive tests ? Description of program activities ? Other indicators that may arise to ascertain program progress Condition The District did not have supporting evidence to document its weekly submission of the reports required under Section 4.2.4 of the grant agreement. Specifically, the District was unable to provide documents to support the number of tests (PCR) and the total positive tests reported.Questioned Costs There were no questioned costs associated with the condition identified.Context The condition was identified as a result of our examination on weekly reports created by the District under Section 4.2.4 and through inquiry with District personnel. Effect Due to the condition identified, we were unable to validate the accuracy of the weekly reports submitted to LACOE as required under Section 4.2.4 of the grant agreement. Cause The condition appears to have materialized due to the District inadequately maintaining files required under the grant agreement. Repeat Finding No Recommendation The District should ensure that meticulous records are maintained with respect to all compliance reporting requirements. Failure to maintain supporting documents for grants could potentially lead to questioned costs that would require the District to return program funds to the sponsoring entity.

50000 (Maintenance of Effort, Significant Deficiency) Federal Program Affected Federal Agency: U.S. Department of Education Pass-through Entity: California Department of Education Federal Program: Special Education Cluster CFDA/ALN: 84.173 & 84.027 (FY 2021-2022) Compliance Requirement: Maintenance of Effort Type of Finding: Significant Deficiency and Non-Compliance Criteria or Specific Requirements The Code of Federal Regulations, Title 34, Subtitle B, Chapter III, Part 300, Subpart C, Section 300.203(a)(1)) states: For purposes of establishing the LEA's eligibility for an award for a fiscal year, the SEA must determine that the LEA budgets, for the education of children with disabilities, at least the same amount, from at least one of the following sources, as the LEA spent for that purpose from the same source for the most recent fiscal year for which information is available: i. Local funds only; ii. The combination of State and local funds; iii. Local funds only on a per capita basis; or iv. The combination of State and local funds on a per capita basis. The State of California Department of Education checks compliance with the federal code through the LEA?s completion of the Report SEMA within the Standardized Account Code Structure Financial Reporting Software Unaudited Actuals module. The Report SEMA calculates the LEA?s maintenance of effort (MOE) compliance by comparing the current year?s applicable expenditures to the most recent year that the LEA met the MOE. Condition The District did not meet the maintenance of effort requirement for the 2021-2022 fiscal year using any of the four tests noted in the federal code.Questioned Costs There were no questioned costs associated with the condition identified. Context The condition was identified as a result of our examination of Report SEMA within the Standardized Account Code Structure Financial Reporting Software Unaudited Actuals reporting package for the 2021-2022 fiscal year.Effect The District did not comply with Code of Federal Regulations, Title 34, Subtitle B, Chapter III, Part 300, Subpart C, Section 300.203(a)(1). Cause The condition appears to have resulted from the District?s decreased expenditure of state and local funds on Special Education programs. Repeat Finding No Recommendation The District should examine if any of the exempt reduction options apply to its situation. If none apply, the District should prepare for a possible reduction in federal Special Education/IDEA funding.