INGLEWOOD UNIFIED SCHOOL DISTRICTLocal Government

Criteria: ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23),(25))) require a local educational agency to have official written documentation that a student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma in order to remove a student from the graduation cohort. A student who is retained in grade, enrolled in a GED program, or leaves school for any other reason may not be counted has having transferred out for the purpose of calculating graduation rate and must remain in the adjusted cohort. Condition: During our testing of compliance and controls over the graduation cohort, we identified two instances in which the District was unable to provide supporting documentation to demonstrate that the students enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. Context: Exceptions were identified for two of the three students sampled. Questioned Costs: None. Cause: Lack of review process to ensure that when a student is removed from the graduation cohort proper documentation is obtained and maintained to support the student’s removal from the graduation cohort. Effect: School site’s graduation rate will be overstated on the school site’s annual report card. Recommendation: We recommend the District train school site staff on allowable documentation to remove students from a graduation cohort as well as regarding other cohort codes. Subsequently the District should assist school sites in developing the record retention process to ensure documentation is available upon request. Lastly, the District should conduct an audit over pupils who have been historically removed from the graduation cohort and ensure that proper documentation is on file to support their removal. If documentation does not exist, then those pupils codes should be revised accordingly. Views of Responsible Officials: The District recognizes the importance of maintaining accurate graduation cohort records and acknowledges the finding. The District is committed to improving procedures to ensure that all cohort removals are supported by appropriate documentation and meet applicable compliance requirements. To address this issue, the District will continue to provide guidance and training to school site staff regarding proper cohort coding practices, allowable supporting records, and documentation standards. In addition, the District will strengthen its review and retention processes to ensure that cohort adjustment documentation is consistently collected, properly reviewed, and maintained in an organized manner for audit purposes. The District will also conduct periodic internal reviews of cohort records to verify the accuracy of both historical and future student removals. Clear procedural expectations and oversight responsibilities will be established to support compliance, improve reporting accuracy, and reduce the risk of recurrence.

Criteria: 2 CFR, section 200.430 states, in part: (i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (vii) 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. 2 CFR, section 200.303 states, in part: The non- Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CSAM Procedure 905 states, in part: Periodic (Semiannual) Certification Employees who work solely on a single federal award or cost objective need only complete a periodic certification. The periodic certification must:  Be prepared at least semiannually.  Be signed by the employee or the supervisory official having firsthand knowledge of the work performed by the employee.  State the employee worked solely on that single federal program or cost objective during the period covered by the certification. Where multiple employees work on the same cost objective, a blanket certification may be used as the documentation for all employees who worked on the cost objective. Personnel Activity Report Except as provided in “Substitute Systems for Time Accounting” … employees who work on multiple activities or cost objectives of which at least one is federal must complete a personnel activity report (PAR) or equivalent documentation. A PAR may be as detailed as a document that identifies the employee’s activity daily by hours, or it may be as simple as a report of the total hours or percentage of hours spent in each categorical program or cost objective. The level of detail can generally be determined by the diversity and variation of the employee’s work activities. The safest approach is to provide more documentation rather than less. Condition: The District has five employees who must complete PARs on a monthly basis. Upon review of the PARs the following deficiencies were noted.  PARs were not filled out properly from April 2025 through June 2025, which required amendment.  Due to errors on the PARs from April 2025 through June 2025, the Districts year end entries to charge salaries and benefits to Title I were incorrect. Context: Exceptions are recurring among the five employees who are required to fill out PAR forms. Questioned Costs: The net overcharge to Title I, Part A was $29,675 for all five employees. Cause: District personnel do not follow the established procedures as to when and how PAR forms must be prepared. In addition, there is a lack of oversight to ensure that PAR forms are collected after the end of each month, filled out accurately, and signed by the employee as well as their supervisor. Effect: Estimated questioned cost of $29,675 for the 2024-25 fiscal year. Recommendation: The District should provide training to employees regarding how to complete PAR forms and enforce timelines. In conjunction, the District should assign an employee who is responsible for reviewing and ensuring that all PAR forms have been collected and signed by the employee and supervisor. Lastly once it has been verified that the PAR form is complete, a copy should be forwarded to Fiscal Services so that they may ratify the salaries and benefits charged to Title I to reflect the percentage noted on the PAR form. Views of Responsible Officials: The District recognizes the finding and is committed to ensuring that all federal time accounting requirements are properly followed for staff funded through Title I programs. The District understands that accurate and complete Personnel Activity Reports (PARs) are necessary to support appropriate salary and benefit charges to federal resources. To address this, the District will reinforce expectations through additional training and support for employees and supervisors on the correct preparation and monthly submission of PAR forms. The District will also strengthen internal review procedures by assigning responsibility for confirming that PARs are completed accurately, collected on time, and signed by both the employee and the supervising administrator. In addition, the District will ensure PAR documentation is consistently forwarded to Fiscal Services to allow for timely review and necessary adjustments so that payroll expenditures align with the actual percentage of time worked on Title I activities.

Criteria: California Department of education Management Bulletin SNP-27-2015 and CACFP-07-2015 require educational agencies operating multiple child nutrition programs to separately account for program revenue and expenses. Condition: During our review expenditures we discovered that the District does not track expenses separately for Child Nutrition Program and Child and Adult Care Food Program (CACFP). The District does not maintain separate invoices, and they do not have an established interprogram vending agreement. Context: Condition was noted in fiscal year 2024-25, occurring in the Cafeteria Fund (Fund 13). Questioned Costs: District overcharged the National School Lunch Program $844,729 and undercharged CACFP. Cause: The District does not have adequate controls in place to ensure that direct costs and indirect costs are consistently allocated to all categorical programs. Effect: Common, shared expenses are not being charged in an equitable, logical manner between programs. Recommendation: The District has been working with consultants and state auditors to establish an interprogram vending agreement to properly move expenses from resource 5310 to 5320 each month or establish controls to track invoices separately for each program. We recommend that once they have determined how these expenses will be tracked that they immediately implement them and ensure that expenses are properly allocated going forward. Views of Responsible Officials: The District acknowledges the finding and is committed to strengthening internal controls over expenditure tracking within the Child Nutrition Program to ensure compliance with all applicable federal and state requirements. Historically, the District rolled up related expenditures through the SACs process. Based on the auditors’ guidance, the District will now track and report these expenses separately to improve transparency and ensure proper classification. The District does not anticipate any financial impact as a result of this change, as it represents a reclassification of costs rather than the incurrence of new expenses. Additionally, the District has been working collaboratively with consultants and state auditors to develop and implement an appropriate inter program vending agreement between the National School Lunch Program and the Child and Adult Care Food Program. This agreement will support the proper allocation and monthly transfer of shared costs between the respective program resources. Additionally, the District will establish improved procedures to ensure expenses and invoices are tracked and maintained separately for each nutrition program, allowing for consistent and equitable cost distribution.

Finding 2024-006: Annual Report Card, High School Graduation Rate (50000) Repeat Finding? This is a repeat of Finding 2023-008. Program Identification: Federal Agency: U.S. Department of Education Pass‐through Entity: California Department of Education Program Names: Title I, Part A Grants: Title I, Part A, Basic Grants Local-Income and Neglected (AL No. 84.010) Criteria: ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25))) require a local educational agency to have official written documentation that a student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma in order to remove a student from the graduation cohort. A student who is retained in grade, enrolled in a GED program, or leaves school for any other reason may not be counted has having transferred out for the purpose of calculating graduation rate and must remain in the adjusted cohort. Condition: During our testing of compliance and controls over the graduation cohort, we identified two instances in which the District was unable to provide supporting documentation to demonstrate that the students enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. Context: Exceptions were identified for two of the four students sampled. Questioned Costs: None. Cause: Lack of review process to ensure that when a student is removed from the graduation cohort proper documentation is obtained and maintained to support the student’s removal from the graduation cohort. Effect: School site’s graduation rate will be overstated on the school site’s annual report card. Recommendation: We recommend the District train school site staff on allowable documentation to remove students from a graduation cohort as well as regarding other cohort codes. Subsequently the District should assist school sites in developing the record retention process to ensure documentation is available upon request. Lastly, the District should conduct an audit over pupils who have been historically removed from the graduation cohort and ensure that proper documentation is on file to support their removal. If documentation does not exist, then those pupils codes should be revised accordingly. Views of Responsible Officials: The District acknowledges the finding and is committed to strengthening controls over graduation cohort documentation. To address this, we will provide targeted training for school site staff on proper cohort coding, allowable documentation, and compliance requirements. Additionally, we will implement a standardized review process to ensure that all student cohort removals have appropriate supporting records and are retained in a centralized system for audit purposes. To further enhance compliance, the District will conduct periodic internal audits to verify the accuracy of past and future cohort removals, updating records as necessary. Clear procedural guidelines will be established, and a designated compliance team will oversee adherence to these protocols. These corrective actions will ensure accurate graduation reporting and prevent recurrence of this issue

Finding 2024-007: Time Accounting (50000) Repeat Finding? This is a partial repeat of Finding 2023-009. Program Identification: Federal Agency: U.S. Department of Education Pass‐through Entity: California Department of Education Program Names: Title I, Part A Grants: Title I, Part A, Basic Grants Local-Income and Neglected (AL No. 84.010) Criteria: 2 CFR, section 200.430 states, in part: (i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (vii) 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. 2 CFR, section 200.303 states, in part: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CSAM Procedure 905 states, in part: Periodic (Semiannual) Certification Employees who work solely on a single federal award or cost objective need only complete a periodic certification. The periodic certification must: Be prepared at least semiannually. Be signed by the employee or the supervisory official having firsthand knowledge of the work performed by the employee. State the employee worked solely on that single federal program or cost objective during the period covered by the certification. Where multiple employees work on the same cost objective, a blanket certification may be used as the documentation for all employees who worked on the cost objective. Personnel Activity Report Except as provided in “Substitute Systems for Time Accounting” … employees who work on multiple activities or cost objectives of which at least one is federal must complete a personnel activity report (PAR) or equivalent documentation. A PAR may be as detailed as a document that identifies the employee’s activity daily by hours, or it may be as simple as a report of the total hours or percentage of hours spent in each categorical program or cost objective. The level of detail can generally be determined by the diversity and variation of the employee’s work activities. The safest approach is to provide more documentation rather than less. Condition: Five employees that had complete PARs for time accounting had the following deficiencies: Salaries and benefits were charged 100% to Title I, Part A for these individuals, each month’s salary was not reconciled to reflect the percentage on their PARs. PARs were only provided for 4 months of the fiscal year, the remaining PAR reports requested were not provided. Context: Exceptions were identified for all five employees who were subject to PAR reporting. Questioned Costs: Auditor is estimating that Title I, Part A, was overcharged by $30,205 because the District did not modify each month’s charges to the actual percentage worked on the program. This overcharge was based on averaging the percentage for the four months of PARs we were provided. Cause: District lacks adequate controls to ensure that time certification documentation is prepared and maintained to support all employees who are paid with federal funds. Effect: Estimated cost questioned of $30,205 for the 2023-24 fiscal year. Recommendation: We recommend that the District comply with 2 CFR, section 200.303, and CSAM Procedure 905, which require that employee time certification forms be maintained for employees who charge time to federal program. Views of Responsible Officials: The District acknowledges this finding and is committed to strengthening internal controls to ensure compliance with federal time accounting requirements. The State and Federal Programs Department has received training on Time and Effort procedures, and additional training is being provided to school sites to reinforce accurate time certification and documentation for federal fund expenditures. To address the deficiencies, the District will shift from an annual to a monthly reconciliation process, ensuring that employee salaries charged to Title I accurately reflect actual work performed. The State and Federal Programs Department will collaborate with the Budget Department to systematically track employees funded through Title I and verify that all required PARs are completed and maintained. These corrective actions will enhance oversight, reduce the risk of discrepancies, and improve compliance with federal regulations. The District is committed to ongoing monitoring and training to prevent recurrence and ensure the integrity of financial reporting.

Finding 2023-008: Annual Report Card, High School Graduation Rate (50000) Program Identification: Federal Agency: U.S. Department of Education Pass‐through Entity: California Department of Education Program Names: Title I, Part A Grants: Title I, Part A, Basic Grants Local-Income and Neglected (AL No. 84.010) ESEA, School Improvement Grant Funding for LEAs (AL No. 84.010) Criteria: ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25))) require a local educational agency to have official written documentation that a student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma in order to remove a student from the graduation cohort. A student who is retained in grade, enrolled in a GED program, or leaves school for any other reason may not be counted has having transferred out for the purpose of calculating graduation rate and must remain in the adjusted cohort. Condition: During our testing of compliance and controls over the graduation cohort, we identified five instances in which the District was unable to provide supporting documentation to demonstrate that the students enrolled in another school or in a educational program that culminates in the award of a regular high school diploma. Context: Exceptions were identified in five of the seven students sampled. Questioned Costs: None. Cause: Lack of review process to ensure that when a student is removed from the graduation cohort proper documentation is obtained and maintained to support the student’s removal from the graduation cohort. Effect: School site’s graduation rate will be overstated on the school site’s annual report card. Recommendation: We recommend the District train school site staff on allowable documentation to remove students from a graduation cohort as well as other cohort codes. Subsequently the District should assist school sites in developing the record retention process to ensure documentation is available upon request. Views of Responsible Officials: Office Managers and Data Clerks need comprehensive training sessions on the importance of the removal of students from a graduation cohort as a federal requirement. These sessions will specifically focus on imparting knowledge about acceptable documentation for the removal of students from a graduation cohort. Staff members will receive guidance on the proper documentation required for various cohort codes, aiming to enhance accuracy in cohort reporting. Secondly, the district will actively support school sites in establishing a record retention process. This involves ensuring that when a student is removed from the graduation cohort, there is consistent and substantiated documentation in place in a centralized drive that can be accessed by all stakeholders. The emphasis lies on maintaining accurate and accessible records to support cohort reporting.

Finding 2023-009: Time Accounting (50000) Program Identification: Federal Agency: U.S. Department of Education Pass‐through Entity: California Department of Education Program Names: Title I, Part A Grants: Title I, Part A, Basic Grants Local-Income and Neglected (AL No. 84.010) ESEA, School Improvement Grant Funding for LEAs (AL No. 84.010) Program Names: Education Stabilization Funds: Elementary and Secondary School Emergency Relief II Fund (AL No. 84.425) Elementary and Secondary School Emergency Relief III Fund (AL No. 84.425) Expand Learning Opportunities Grant ESSER II State Reserve (AL No. 84.425) Criteria: 2 CFR, section 200.430 states, in part: (i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (vii) 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. 2 CFR, section 200.303 states, in part: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CSAM Procedure 905 states, in part: Periodic (Semiannual) Certification Employees who work solely on a single federal award or cost objective need only complete a periodic certification. The periodic certification must: • Be prepared at least semiannually. • Be signed by the employee or the supervisory official having firsthand knowledge of the work performed by the employee. • State the employee worked solely on that single federal program or cost objective during the period covered by the certification. Where multiple employees work on the same cost objective, a blanket certification may be used as the documentation for all employees who worked on the cost objective. Personnel Activity Report Except as provided in “Substitute Systems for Time Accounting” … employees who work on multiple activities or cost objectives of which at least one is federal must complete a personnel activity report (PAR) or equivalent documentation. A PAR may be as detailed as a document that identifies the employee’s activity daily by hours, or it may be as simple as a report of the total hours or percentage of hours spent in each categorical program or cost objective. The level of detail can generally be determined by the diversity and variation of the employee’s work activities. The safest approach is to provide more documentation rather than less. Condition: The District lacks procedures and controls to ensure that employees being funded from federal funds complete their personal activity reports monthly as well as ensuring semi-annual time certifications are completed in a timely manner. Context: Our total sample consisted of 44 employees, and for all 44 employees it took the District months to provide time accounting documentation. In some instances, the District had to go back and prepare the time accounting documentation, because some of the employees sampled were no longer employed by the District. Questioned Costs: No questioned costs. Cause: District lacks adequate controls to ensure that time certification documentation is prepared and maintained to support all employees who are paid with federal funds. Effect: Lack of proper controls to ensure that time certification documentation is prepared may result in the District having to go back and recreate documentation for individuals who are no longer employed by the District. In addition, lack of time documentation may result in a questioned cost. Recommendation: We recommend that the District comply with 2 CFR, section 200.303, and CSAM Procedure 905, which require that employee time certification forms be maintained for employees who charge time to federal program. Views of Responsible Officials: The State and Federal Programs Department at the recommendation of FPM began Time and Effort Procedures training on December 6, 2023, with the Office Managers and Administrative Secretaries to emphasize the critical importance of accurate time certification records for federal fund expenditures. In addition, the State and Federal Programs (SFP) Department and Budget Department are collaborating on identifying the Employees charged to Title I. Currently the Employee list for July 2023- December 2023 have been provided to SFP by the Budget Department. SFP has sent the Time and Effort forms to the Departments: Leads, Office Managers with a deadline for collection in January. The district commits to collecting semi-annual time and effort documentation within 10 business days of when the effort window closes.

Finding 2019-011: Time Certifications (30000, 50000)This is a partial repeat of Finding 2018-011.CFDA #84.010 and 84.367?Title I and Title II, U.S. Department of Education, California Department ofEducationCriteria: 2 CFR, section 200.430 states, in part:(i) Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records that accuratelyreflect the work performed. These records must:(vii) Support the distribution of the employee's salary or wages among specific activities or costobjectives 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 activitieswhich are allocated using different allocation bases; or an unallowable activity and a direct orindirect cost activity.2 CFR, section 200.303 states, in part:The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award in compliancewith Federal statutes, regulations, and the terms and conditions of the Federal award.CSAM Procedure 905 states, in part:Periodic (Semiannual) CertificationEmployees who work solely on a single federal award or cost objective need only complete a periodiccertification. The periodic certification must:o Be prepared at least semiannually.o Be signed by the employee or the supervisory official having firsthand knowledge of the workperformed by the employee.o State the employee worked solely on that single federal program or cost objective during the periodcovered by the certification.Where multiple employees work on the same cost objective, a blanket certification may be used as thedocumentation for all employees who worked on the cost objective Personnel Activity ReportExcept as provided in ?Substitute Systems for Time Accounting?? employees who work on multipleactivities or cost objectives of which at least one is federal must complete a personnel activity report (PAR)or equivalent documentation.A PAR may be as detailed as a document that identifies the employee?s activity daily by hours, or it may beas simple as a report of the total hours or percentage of hours spent in each categorical program or costobjective. The level of detail can generally be determined by the diversity and variation of the employee?swork activities. The safest approach is to provide more documentation rather than less.Condition: Based on our review of the District?s expenditures for its major federal programs, we noted inadequatecontrols over time certifications for the Title I and Title II programs as follows:? Title I ? CFDA 84.010: The District did not provide time certification records for 7 of 25 employees selectedfor audit who were paid with Title I funds.? Title II ? CFDA 84.367: The District did not provide time certification records for 9 of 25 employees selectedfor audit who were paid with Title II funds.This appears to be a systemic weakness. The sample was not statistically valid.Cause: The District does not have adequate controls in place to ensure that time certification documentation isprepared and maintained to support all employees who are paid with federal funds.Context: The error appears to be systemic. The District could not provide documentation for 7 of 25 employeescharged to Title I and 9 of 25 employees charged to Title II.Questioned Cost: A total of $168,413 for Title I and $9,250 for Title II is in question because the District did notmaintain proper time certification documentation for employees who were paid with federal funds.Recommendation: We recommend that the District comply with 2 CFR, section 200.303, and CSAM Procedure 905,which require that employee time certification forms be maintained for employees who charge time to federalprograms.Views of Responsible Officials: The Business Services Division will work with Education Services Division, Officeof State and Federal Program and the assigned coordinator to ensure program compliance. Time certifications aredone semi ?annually or annually depending on funding, and documents are stored in the Categorical office.

Finding 2019-012: Federal Program Oversight (30000, 50000)This is a partial repeat of Finding 2018-012.CFDA #84.010 - Title I, U.S. Department of Education, California Department of EducationCriteria:34 CFR, section 200.25(b) states, in part:Eligibility(1) A school may operate a schoolwide program if?(i) The school?s LEA determines that the school serves an eligible attendance area or a participatingschool under section 1113 of the ESEA; andFor the initial year of the schoolwide program?(A) The school serves a school attendance area in which not less than 40 percent of the children arefrom low-income families; or(B) Not less than 40 percent of the children enrolled in the school are from low-income families.2 CFR, section 200.303 states, in part:The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award in compliancewith Federal statutes, regulations, and the terms and conditions of the Federal award.Condition: During our review of the District?s major federal programs, we noted the following deficiencies:? Title I ? CFDA 84.010 ? The District did not provide supporting documentation to explain variances betweenthe percentages of children from low income families shown on the District's Consolidated Application?Title I, Part A School Allocations Report and the percentages shown on the California Longitudinal PupilAchievement Data System(CALPADS)report.Questioned Cost: NoneContext: The errors appear to be a systemic weakness in internal controls.Effect: Federal funding could be jeopardized if the documentation necessary to demonstrate compliance withapplicable federal requirements is not maintained and controls are not in place to support compliance. There are noquestioned costs as a result of this finding.Cause: The District was unable to provide supporting documentation to demonstrate that the percentage shown onthe School Allocations Report was calculated correctly for Title I.Recommendation: We recommend that the District maintain source documentation to demonstrate that its federalprograms met all compliance and eligibility requirements for Title I and implement internal control procedures toensure compliance with applicable federal requirements.Views of Responsible Officials: The Education Services Division, Office of State and Federal Program and BusinessServices are recruiting a State and Federal Budget Analyst to ensure compliance. The Executive Director of SpecialProjects continues to maintain oversight and ensures policies and procedures for the program.

Finding 2019-013: Equipment Management (20000, 30000, 50000)This is a repeat of Finding 2018-013.CFDA #84.010?Title I, U.S. Department of Education, California Department of EducationCriteria:2 CFR, section 200.33 states:Equipment means tangible personal property (including information technology systems) having a useful lifeof more than one year and a per-unit acquisition cost which equals or exceeds the lesser of the capitalizationlevel established by the non-Federal entity for financial statement purposes, or $5,000.2 CFR, section 200.313(d) states, in part:Management requirements. Procedures for managing equipment (including replacement equipment), whetheracquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meetthe following requirements:(1) Property records must be maintained that include a description of the property, a serial numberor other identification number, the source of funding for the property (including the FAIN),who holds title, the acquisition date, and cost of the property, percentage of Federalparticipation in the project costs for the Federal award under which the property was acquired,the location, use and condition of the property, and any ultimate disposition data including thedate of disposal and sale price of the property.(2) A physical inventory of the property must be taken and the results reconciled with the propertyrecords at least once every two years.(3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, ortheft of the property. Any loss, damage, or theft must be investigated.Condition: Based on the equipment listing provided by the District for Title I, we noted that no new equipment items($5,000 or more) were acquired in FY 2018-19. The District is required to conduct a physical inventory of properlyand those results reconcile to the property records every two years. Based on our inquiry with District officials, wenoted that a physical inventory has not been conducted.Questioned Cost: N/AContext: Problem appears to be systemic.Effect: Inadequate controls over equipment could lead to noncompliance with state and federal requirements andmisappropriation of funds. There are no questioned costs as a result of this finding.Cause: The District has not conducted a full physical inventory of property and reconciled it with the District's records.Recommendation: We recommend that the District strengthen its controls over its equipment-management systemand ensure that its equipment inventory listing is complete and accurate.Views of Responsible Officials: The office of State and Federal Programs now inventories all equipmentelectronically. All items are scanned, labeled, and recorded in inventory software that can be made easily accessiblein case of any future audits.

Finding 2019-014: Title I ? Graduation Rate Data (50000)CFDA #84.010?Title I, U.S. Department of Education, California Department of EducationCriteria: LEAs must report graduation rate data for all public high schools at the school, LEA, and State levels usingthe 4-year adjusted cohort rate and, at an SEA?s or LEA?s discretion, extended-year adjusted cohort rates. Graduationrate data must be reported both in the aggregate and disaggregated by subgroup in section 1111(c)(2) of the ESEAusing a 4-year adjusted cohort graduation rate (and any extended-year adjusted cohort rates). (ESEA sections1111(h)(1)(C)(iii)(II) and 8101(25), (23)).To remove a student from the cohort, a school or LEA must confirm, in writing, that the student transferred out,emigrated to another country, transferred to a prison or juvenile facility, or is deceased. To confirm that a studenttransferred out, the school or LEA must have official written documentation that the student enrolled in another schoolor in an educational program that culminates in the award of a regular high school diploma. A student who is retainedin grade, enrolls in a GED program, or leaves school for any other reason may not be counted as having transferredout for the purpose of calculating graduation rate and must remain in the adjusted cohort (ESEA sections1111(h)(1)(C)(iii)(II) and 8101(25), (23)).Condition: The District was unable to provide written documentation to support the number of students removedfrom the cohort.Questioned Cost: None.Context: We sampled eight students removed from the cohort in the 2018-19 school year, and documentation waslacking for all eight.Effect: Graduation rate data may be inaccurate and future funding could be jeopardized.Cause: The District did not maintain adequate records to report graduation rate data.Recommendation: The District should implement a review process to ensure that written documentation is obtainedand kept on file to support the removal of students from the cohort.Views of Responsible Officials: The District will work with the Education Services Division, Executive Director ofSecondary Education to implement a review process to ensure that written documentation is obtained and kept on fileto support the removal of students from the cohort.

Finding 2019-015: Private School Allocations (50000)CFDA #84.367 ? Title II, Part A, U.S. Department of Education, California Department of EducationCriteria: LEAs or other eligible entities receiving financial assistance under an applicable program must provideeligible private school children and their teachers or other educational personnel with equitable services or otherbenefits under the program. Before an agency or consortium makes any decision that affects the opportunity of eligibleprivate school children, teachers, and other educational personnel to participate, the agency or consortium must engagein timely and meaningful consultation with private school officials. Expenditures for services and benefits to eligibleprivate school children and their teachers and other educational personnel must be equal on a per-pupil basis to theexpenditures for participating public school children and their teachers and other educational personnel, taking intoaccount the number and educational needs of the children, teachers and other educational personnel to be served(Sections 8501 of ESEA (20 USC 7881); 34 CFR sections 299.6 through 299.9).Condition: The District was unable to provide the Title II, Part A private school allocation calculation. As a result,we were unable to verify that planned expenses were actually made, or to verify allocation method.Questioned Cost: N/AContext: Problem appears to be systemic.Effect: The District allocation of Title II, Part A funds to private schools may be inaccurate.Cause: There was a lack of oversight and procedures in place to keep allocation and supporting documentation todemonstrate the allocations were met.Recommendation: We recommend that the District implement oversight procedures to ensure allocation calculationsare met and that supporting documentation is kept on file to demonstrate that allocations were met.Views of Responsible Officials: The Education Services Division, Office of State and Federal Program and BusinessServices are recruiting a State and Federal Budget Analyst to ensure allocation calculations are met and that supportingdocumentation is kept on file to demonstrate that allocations were met.

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GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION