Adelanto Elementary School District

Criteria or Specific Requirements Title 2, Code of Federal Regulations (CFR), Part 200, Subpart D, Section 200.318(a) requires recipients and subrecipients of Federal awards to maintain and use documented procurement procedures that conform to standards identified in Title 2, CFR, Part 200, Subpart D, Section 200.318. This includes the retention of all procurement related documents in connection with federal awards. Condition The District was unable to provide procurement documents, including copies of bid documents and contracts for a sampled covered transaction. Cause The condition appears to have materialized due to the District not adhering to its federal procurement policy. Effect The District did not comply with general procurement standards required by Title 2, CFR Section 200.318(a) and the District policy. Questioned Costs There were no questioned costs identified related to the condition identified above. Context Total population of 16 transactions were identified and 4 were sampled that were haphazardly selected. Testing result in a 25% exception rate which is 1 out of the 4 samples selected for testing. Repeat Finding No. Recommendation The District should ensure that all federal procurement transactions are aligned with its procurement policy. As required under the District’s procurement policy, the District should retain all procurement related documents.

5000 (Allowable Costs/Cost Principles and Equipment Real Property Management, Significant Deficiency) Federal Program Affected Federal Agency: U.S. Department of Education Pass‐through Entity: California Department of Education Federal Program: Education Stabilization Fund (ESF) ALN: 84.425C, 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 pass‐through 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 $20,760 in capital expenditures charged to the program that was not preapproved by CDE. Questioned Costs A total of $20,760 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 each of the programs audited. 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 Yes. See prior year finding 2022‐002. Recommendation The District should become familiar with all of the compliance requirements of this program and other Federal programs. 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. Corrective Action Plan and Views of Responsible Officials The District will implement Federal Uniform Guidance procurement procedures to ensure all compliance requirements are being implemented for Federal funds expenditures. Purchasing controls will be implemented to receive prior approval for capital purchases with Federal funds.

FINDING 2022-002 EDUCATION STABILIZATION FUND (50000) Federal Agency: U.S. Department of Education Pass through Entity: California Department of Education Program Names: Elementary and Secondary School Emergency Relief I, II, III (ESSER, ESSER II, ESSER III) (Assistance Listing 84.425, D, U) Criteria: Consistent with 2CFR Section 200.311 (real property), Section 200.313 (equipment), and Section 200.439 (equipment and other capital expenditures) Education Stabilization Funds may be used to purchase equipment. Capital expenditures for general and special purpose equipment purchases are subject to prior approval by the Department of Education or the pass-through entity. Condition: The District purchased numerous equipment items above the capital threshold for federal purchases but did not obtain approval from the California Department of Education. Questioned Costs: Purchases totaling $329,699.90 were made for equipment above the capital threshold without CDE approval. Context: The finding is limited to purchases above the capital threshold requiring approval. This is not a repeat finding. Cause: The District was unaware of the requirement. Effect: The funds spent on this purchase may be subject to review or return to the awarding agency. Recommendation: We recommend the District submit requests for approval for the equipment or find another allowable funding source for the purchases. CDE has stated that it will accept requests after the fact. Views of responsible officials: Staff and management will ensure that the District submits requests for approval for capital expenditures from the California Department of Education prior to purchases.

FINDING 2022-003 INADEQUATE SUPPORT FOR SALARIES AND WAGES- TIME CERTIFICATIONS NOT MAINTAINED (50000) Federal Agency: U.S. Department of Education Pass through Entity: California Department of Education Program Names: Elementary and Secondary School Emergency Relief I, II, III (ESSER, ESSER II, ESSER III) (Assistance Listing 84.425, D, U). Title I (Assistance Listing 84.010) Criteria: 2 CFR 200.430 requires that an LEA must maintain time and effort distribution records that support the distribution of the employee?s salary or wages among specific activities or cost objectives. 2CFR, section 225, appendix B, Section 8(h) states in part: Support of salaries and wages?These standards regarding time distribution are in addition to the standards for payroll documentation. (1) Charges to Federal awards for salaries and wages, whether treated as direct or indirect costs, will be based on payrolls documented in accordance with generally accepted practice of the governmental unit and approved by a responsible official(s) of the governmental unit. (2) No further documentation is required for salaries and wages of employees who work in a single indirect cost activity. (3) Where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employee worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. 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 provided approved time sheets for only 3 employees out of 20 selected that were paid from ESSER funding. The District provided 9 of 10 time accounting records that included PARS for Title I. Context/Questioned Cost/Effect: The District did not provide time certification records for 17 of the 20 employees selected for review, who were paid with Education Stabilization Funds. As a result, the amount of $736,116.27 is in question. This finding occurred in the 2021-22 fiscal year and is not a repeat finding. The District did not provide time certification records for 1 of 8 employees selected for review, who was paid with Title I funds, as a result, the amount of $ 91,794 is in question. Cause: The District does not have adequate controls in place to ensure that time certification documentation is prepared and maintained to support all employees who are paid with federal funds. Recommendations: We recommend the District comply with Title 2, CFR 200.303, and CSAM Procedure 905 which require that employee time certification forms be maintained for employees who charge time to federal programs. Views of Responsible Officials: Management will ensure that the District does have adequate controls in place and comply with Federal rules and guidelines.

FINDING 2021-001: EDUCATION STABILIZATION FUND-PARTICIPATION OF PRIVATE SCHOOL CHILDREN (50000) Program Identification: Federal Agency: U.S. Department of Education Pass-through Entity: California Department of Education Program Names: Elementary and Secondary School Emergency Relief (ESSER) (AL No. 84.425D) Governor?s Emergency Education Relief (GEER) Fund (AL No. 84.425C) Criteria: For programs under ESSER I and GEER I, an LEA that receives funds under one or both programs must provide equitable services in the same manner as provided under section 1117 of Title I, Part A of the ESEA (20 USC 6320) to students and teachers in private schools as determined in consultation with private school officials (section 18005(a) of the CARES Act. To meet this requirement, an LEA must determine the proportional share of funds available for equitable services. Condition: The District did not offer equitable services from ESSER I and GEER I to private schools in the same manner as provided under Title I as determined in consultation with private school officials. Cause: The District was unaware of the necessity to offer the funding in the same manner to private schools in the same manner. Questioned Cost: Based on 2019-20 Title I proportional share allocations, minimum questioned cost is estimated to be $4,263.58 Context: This finding is limited to the 2020-21 fiscal year. Subsequent ESSER and GEER funding to the LEA does not have this requirement as private schools are directly funded. Effect: The District did not offer funding from ESSER I and GEER I to private schools. Recommendation: Consistent with sections 8501 and 8503 of ESEA, a private school may file a complaint directly with the California Department of Education (CDE). Views of Responsible Officials: Staff will ensure equitable services are offered to private schools based on proportional shares of funds.

GSA_MIGRATION

GSA_MIGRATION